The Liechtenstein private foundation (Private Stiftung) is still a well-known instrument for private estate planning in Liechtenstein, especially for foreign investors. After recent legislative changes in Liechtenstein, a foundation may adopt the form of an alternative investment fund (AIF) and therefore access fund taxation rules in Liechtenstein and abroad. This new compound of a corporate, regulatory and tax hybrid vehicle also offers interesting opportunities for setting up a financial holding company without operative functions.
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The firms made senior hires in Los Angeles and Cleveland respectively; in other news, South Korea reported an 11% rise in tax income, fuelled by a corporation tax boom
While the manual should be consulted for any questions around MAPs, the OECD’s Sriram Govind also emphasised that the guidance is ‘not a political commitment’
The landmark Indian Supreme Court judgment redefines GAAR, JAAR and treaty safeguards, rejects protections for indirect transfers and tightens conditions for Mauritius‑based investors claiming DTAA relief
As tax teams face pressure from complex rules and manual processes, adopting clear ownership, clean data and adaptable technology is essential, writes Russell Gammon, chief innovation officer at Tax Systems