-
Laetitia Borucki of Bonn Steichen & Partners believes fund managers should review the potential tax impacts relating to residency, VAT and carried interest that are included in Luxembourg’s draft law to implement the EU Alternative Investment Fund Managers Directive. The creation of a new type of partnership is also to be considered.
-
As was recently acknowledged by Monica Bhatia, who heads the OECD’s Global Forum on Transparency and Exchange of Information, “we are seeing a rise in tax transparency, and it’s only going in one direction: more transparency”. Mark Friezer, partner at Clayton Utz in Sydney, explores the latest disclosure requirements being imposed on taxpayers in Australia.
-
As we approach the 10-year anniversary of real estate investment trusts (FIBRAs/REITs) being introduced in Mexico, Alfredo Sánchez and Roberto Padilla Ordaz of Chevez, Ruiz, Zamarripa y Cia track the regime’s development and explain why these investment vehicles have become more attractive in recent years.
-
The OECD’s Base Erosion and Profit Shifting (BEPS) project issued a report in February 2013, which confirmed that the present international tax rules are not effective: “There is increased segregation between the location where actual business activities take place and the location where profits are reported for tax purposes.” David Spencer, formerly a senior adviser and head of transfer pricing for the Tax Justice Network, explores the viability of unitary taxation and questions whether it is a realistic option, considering the way international commerce operates.
-
Aneta Blazejewska-Gaczynska of Ernst & Young looks at how recent hearings from the Polish courts and the planned changes to the law affect transfer pricing
-
Carbon pricing is increasingly becoming part of the BRICS’ strategy to tackle climate change. Emma Powell examines how these countries are implementing it and what effect it will have on businesses.
-
Stuart Adam and David Phillips of the UK Institute for Fiscal Studies argue that the EU’s VAT reform plans could go much further in looking to abolish exemptions and reduced rates.
-
The increasing sophistication of transactions performed between taxpayers has raised concerns among legislators about the recurrent manipulation of the terms and conditions of such transactions as a way of reducing the tax impacts, thus distorting the objectives of the tax systems. Rui Guedes Henriques, Tiago Almeida Veloso and Ana Filipa Janine of Baker Tilly look at the VAT anti-abuse rules introduced in the 2012 budget to address these concerns.
-
Roberto Carlos Rivas, Carolina Alexandres and Gabriel Bernal of PwC look at the changes to transfer pricing legislation which came into force in September last year.
-
Nick Skerrett and Matthew Rees, of PwC, explain why the European Court of Justice’s (ECJ) ruling in the case of Wheels Common Investment Fund Trustees v HMRC means the question of VAT on investment management fees in the context of pensions remains unresolved and why taxpayers should not withdraw their claims just yet.
-
Jens Wittendorf, of Deloitte Denmark, examines a recent dispute in the National Tax Tribunal (NTT) which highlights how unilateral anti-hybrid legislation can have the unintended consequence of eroding the domestic tax base.