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Corporate Tax Archive

  • December 2014

    The big moves of 2014

    December 19, 2014

    A string of departures by senior Internal Revenue Service figures dominated the comings and goings among tax professionals in 2014.

  • New Spanish corporate income tax: The holding regime

    December 18, 2014

    Jose Maria Garcia-Valdecasas Alloza, partner at Balaguer-Morera & Asociados and assistant lecturer at the University of Barcelona, explores upcoming changes to the Spanish tax regime, which has not been comprehensively reformed since 2004.

  • US extenders Bill passes Senate, awaits Obama signature

    December 18, 2014

    The US Senate voted this week to approve a one-year retroactive extension of certain temporary tax provisions that expired at the end of last year, including the research and experimentation credit.

  • Bank loss relief restriction: UK financial services sector takes pre-election hit

    December 17, 2014

    COMMENT: As we look to another general election in the UK in 2015, the latest Autumn Statement contained a further measure affecting the financial services sector. Whether this represents sensible long-term tax policy or is another short-term political ploy to appease voter antipathy by punishing the banks is something for you to decide.

  • Criminal charges for Luxembourg leaker will not deter whistleblowers

    December 17, 2014

    Antoine Deltour, the former PwC auditor who leaked thousands of the company’s documents into the public domain has been charged with a string of offences including theft.

  • European Commission to seek information on tax rulings from all member states

    December 17, 2014

    The European Commission has expanded its state aid inquiry into tax rulings to cover all 28 EU member states.

  • Thomson Reuters honours Taxologists

    December 16, 2014

    Regulatory complexity and globalisation aren’t the only factors changing the landscape of tax.

  • China streamlines taxpayer services

    December 16, 2014

    China has been accelerating its fiscal and tax reforms in recent years. The central government is keen to establish a healthy fiscal and tax system to help optimise allocation of resources, establish a fair market playground, and ultimately achieve prosperity of the nation. Wang Jun, Minister of Taxation of the People's Republic of China, outlines how the government is achieving this.

  • Kazakhstan amends tax code from 2015

    December 16, 2014

    Kate Habershon and Bakhytzhan Kadyrov of Morgan Lewis in Kazakhstan examine the potential impact on business of the country’s draft tax code.

  • The Global Tax 50 2014

    December 16, 2014

    Now in its fourth year, International Tax Review's Global Tax 50 provides a rundown of the who’s who of the tax world. One way or another, the individuals and organisations on this list have had an impact or influence on taxation that will be felt beyond, or outside of, the 12 month period covered by this list.

  • Netherlands court reinforces ECJ position on Dutch fiscal unity regime

    December 12, 2014

    Judgments in three cases by the Court of Appeals Amsterdam (CAA) yesterday have stated that the Netherlands’s restrictions on its fiscal unity rules go against European freedom of establishment principles.

  • New Indonesian tax minister targets transfer pricing to collect $112 billion in 2015

    December 12, 2014

    Following his appointment by Indonesia’s Finance Minister Bambang Brodjonegoro on December 1, new acting director general of taxation Mardiasmo has indicated his intention to improve Indonesia’s tax collection record by gaining access to taxpayers’ bank accounts.

  • UK diverted profits tax reaction: Don’t jump the gun, George

    December 12, 2014

    The UK government has published draft legislation for the diverted profits tax (DPT) – dubbed the ‘Google tax’ – announced by George Osborne, Chancellor of the Exchequer, in last week’s Autumn Statement. The consensus is that the UK would be better served waiting for the delivery of international initiatives on tackling aggressive tax avoidance.

  • OECD tax revenues approaching pre-crisis levels

    December 11, 2014

    Tax burdens in the OECD rose 0.4 percentage points in 2013 to an average of 34.1% of GDP, following rises of 0.3 percentage points in both 2012 and 2011.

  • Learning from Lone Star: What the company’s second win in Korean court can teach MNCs

    December 10, 2014

    Lone Star emerged as a winner for the second time in a case against the Korean tax authorities in the Seoul district court in late November. The court ruled that the Namdaemun District tax office owes the American-owned private equity firm $159 million (177.2 billion won) of previously collected capital gains tax on the company’s sale of its 51% stake in Korea Exchange Bank (KEB) in 2011.

  • Tax tips for multinationals in the Netherlands

    December 09, 2014

    There are only a few weeks before another new year. Now is an opportune moment to review your tax strategy and to consider whether Dutch tax laws require your company to take action before January 1 2015. The next few weeks can also be used to prepare for anticipated new tax legislation in the Netherlands.

  • China: You can download the latest edition of our guide now

    December 08, 2014

    The 4th edition of China - Looking Ahead is available as a downloadable pdf. It features articles on how China regards the BEPS project, the progress of the VAT reforms and what China expects from multinationals on transfer pricing.

  • Brazil Ministry of Finance reduces threshold rate for tax haven classification

    December 05, 2014

    The Ministry of Finance this week published Ordinance MF 488/14 in the Official Gazette, which reduces from 20% to 17% the threshold income tax rate for defining the concepts of low-tax jurisdictions and privileged tax regimes.

  • 17 Asian countries meet in Australia to create a new regional tax taskforce

    December 04, 2014

    From November 24 to 27, Chris Jordan, commissioner of the Australian Tax Office (ATO), hosted tax administrators from 17 Asian member countries including tax leaders from key trade partners Japan and China at the Study Group on Asia Tax Administration in Research (SGATAR). The group of delegates agreed to form a regional task force to share best practices and information.

  • Ashok Lahiri heads up new committee on Indian tax and trade

    December 04, 2014

    In his Budget Speech 2014-15, Indian Finance Minister Arun Jaitley announced the setting up of a committee to interact with trade and industry and ascertain areas where greater clarity on tax laws is required.

  • Good news for investors as Spain changes dividend legislation after EC pressure

    December 04, 2014

    Spain has elected to change its dividend and capital gains legislation after pressure from the European Commission (EC).

  • Autumn Statement 2014: Osborne stresses compliance as key part of pro-business regime

    December 03, 2014

    Delivering his Autumn Statement today, George Osborne announced new anti-avoidance measures for international businesses – including a 25% diverted profits tax – and repeated his statement that the UK is host to an environment of “low taxes, but taxes that will be paid”.

  • Liechtenstein: Private foundation funds as holding companies – a new (hybrid) tax vehicle?

    December 03, 2014

    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.

  • Weinberger to drive Business Roundtable’s tax work

    December 02, 2014

    EY’s chairman and chief executive officer, Mark Weinberger, who has worked for two US presidents, will lead the efforts of his fellow business leaders in the US to ensure Congress passes legislation on tax extenders and tax reform.

  • David Patterson steps up at Chapman Tripp

    December 01, 2014

  • The attractiveness of Ireland’s ICAV regime

    December 01, 2014

    On July 29 2014, the Irish Government published the Irish Collective Asset Management Vehicle Bill 2014 (the ICAV Bill). The ICAV Bill, when enacted, will provide for a corporate vehicle structure specifically designed to meet the needs of the global funds industry with several advantages over the existing corporate structure (that is, the public limited company (plc)) for collective investment schemes in Ireland. The Irish Government has indicated that the ICAV Bill will be enacted before the end of 2014.

International Correspondents