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Corporate Tax

Corporate Tax archive
  • Taxpayers get Indian MAT reprieve for now; Aberdeen case delayed until Castleton verdict

    July 02, 2015

    Tax demands on foreign companies to pay India’s controversial minimum alternate tax (MAT) have been suspended until the Justice A P Shah Panel submits a report to the government on issues with the tax.

  • BEPS implementation in the US - Now comes the hard part

    June 30, 2015

    While the OECD has political backing and momentum behind it, the organisation has no binding authority to implement legislation, so the engagement of key jurisdictions including the US will be central to the project's ultimate success. Ryan Dudley, partner at Friedman, explains why the hard yards still lie ahead.

  • Financial Services Supplement 2015 now available

    June 29, 2015

    Leading advisers provide insights on the latest financial services tax issues from jurisdictions around the world.

  • Mauritius joins Multilateral Convention for Mutual Administrative Assistance in Tax Matters

    June 24, 2015

    Vishnu Lutchmeenaraidoo, the Mauritius Minister of Finance and Economic Development, has added his country's name to the list of those that have signed up to the Multilateral Convention for Mutual Administrative Assistance in Tax Matters.

  • Foreign pension funds with US investments: Tax classification

    June 23, 2015

    The tax classification of a foreign pension fund investing in the United States has major implications in terms of who is subject to tax, the applicable tax rate and the associated reporting obligations. Francis Helverson of WTS explains why pension funds with certain characteristics may have significant advantages over other pension funds as well as over other types of foreign investors.

  • French tax treatment of foreign dividends and interplay with fundamental EU freedoms

    June 23, 2015

    French corporate tax legislation stipulates that distributions of profits from a subsidiary to a French parent company are not, in principle, taxed at the parent. Excluded from this, however, is a 5% proportion, which represents the charges incurred by the French parent company in connection with its holding in the subsidiary. These charges are not to be deductible because they serve the realisation of non-taxable income by the French parent company, namely the distribution of profits from its subsidiaries.

  • Tightened tax rules likely to hit Swedish real estate sector

    June 23, 2015

    The value of real estate in Sweden has been on the rise for a long time and foreign investments in Swedish real estate are substantial. The transaction volume for Q1 2015 amounted to approximately €2.3 billion, with foreign buyers accounting for 25% of this. The Swedish real estate market is often seen as a ‘safe haven’ but changes in the tax regime are expected which could alter the jurisdiction’s attractiveness in the eyes of foreign investors.

  • Common tax base at fore of European Commission's plans for corporate taxation

    June 17, 2015

    The European Commission launched its much-anticipated Action Plan on Corporate Taxation today, basing it on the idea of the Common Consolidated Corporate Tax Base as a 'holistic solution to corporate tax reform' and the principles of ensuring effective taxation and increasing transparency.

  • EC publishes Belgium excess profit regime state aid decision; issues injunctions to other member states

    June 12, 2015

    The European Commission (EC) has published in its Official Journal a notification about its investigation into whether Belgium’s excess profit tax ruling system constitutes state aid and has ordered Estonia and Poland, along with 15 other member states, to provide more information on their tax ruling practices.

  • Have your say on International Tax Review

    June 12, 2015

    At International Tax Review, we think it is important that you, our subscribers and regular readers, get the opportunity to share your views on what we write, how we look and the service you receive.

  • Hatch and Ryan voice US BEPS concerns; urge Lew not to forget Congress in discussions

    June 10, 2015

    The Republicans leading the US Congress’ two tax-writing committees have called on Jacob Lew, Treasury Secretary, to “remain engaged with Congress” as proposals related to the OECD base erosion and profit shifting (BEPS) project continue to be developed.

  • OECD publishes model legislation for CBCR implementation

    June 08, 2015

    The implementation package has brought country-by-country reporting closer for taxpayers.

  • What foreign investors need to know about Italy’s draft ‘internationalisation decree’

    June 04, 2015

    The Italian government has issued the final draft of its ‘internationalisation decree’ (the Decree), which gives practical application to sections of the tax framework approved by the Italian parliament last year (Law 23/2014). Certain provisions in the package will impact foreign investors in real estate in particular.

  • New Argentina-Chile tax treaty creates fresh structuring opportunities

    June 02, 2015

    Argentina and Chile have signed a new double tax treaty to replace the treaty unilaterally terminated by Argentina in 2012. Ignacio Rodriguez and Andres Edelstein of PwC in Argentina outline the new structuring opportunities that are available for taxpayers.

  • ITR launches app!

    June 01, 2015

    The International Tax Review app is now available! International Tax Review subscribers can now download the ITR app, giving them full access to the latest ITR articles while they are on the go.

  • ECJ clarifies German case on investment fund lump-sum taxation

    May 28, 2015

    In its judgment dated May 21 2015 (Wagner-Raith) the European Court of Justice (ECJ) confirmed that the German lump-sum taxation according to section 18 paragraph 3 of the German Foreign Investment Act (GFIA), as effective until the end of 2003, is within the scope of the standstill clause of article 57, EC Treaty.

  • The Brockman brief: UK diverted profits tax: The extrapolation effect

    May 27, 2015

    The UK's diverted profits tax (DPT) was developed, and enacted, quickly in the weeks leading to the general election. The legislation was a two-pronged attack: on transactions having insufficient economic substance and the avoidance of permanent establishment (PE). The legislation went into effect April 1 2015 and there have been hints that other countries are looking at similar moves; but exactly what tax doctrines will other countries adopt to achieve similar objectives?

  • BEPS: Improving data, economic analysis and measurement

    May 27, 2015

    It is stating the obvious to say that current international efforts to tackle base erosion and profit shifting (BEPS) have attracted a great deal of global attention. Since the OECD and G20 countries, working together on an equal footing, adopted a 15-point action plan to address BEPS in September 2013, the focus on this issue has steadily grown. David Bradbury, head of the tax policy and statistics division at the OECD Centre for Tax Policy and Administration, and the man overseeing this aspect of the project, provides exclusive insight into an action point that has not always received as much attention as other items in the Action Plan.

  • India: Changing perceptions through administrative evolution

    May 27, 2015

    Ashwani Mehta, former Chief Commissioner of Income Tax at the Indian Revenue Service, who retired in February after more than 35 years at the IRS department, assesses recent developments in Indian income taxation.

  • ETFs - preparing for future tax challenges

    May 27, 2015

    Exchange traded funds (ETFs) have been a huge success growing far beyond their initial function of tracking large liquid indices in developed markets. Global ETFs now hold more than $2.9 trillion of assets in upwards of 5,400 products listed on 60 exchanges. Marie Coady, financial services tax partner at PwC in Ireland, tackles the associated tax and regulatory challenges.

  • Substance-over-form in China's GAAR

    May 27, 2015

    Scott Heidecke and Flora Luo of Nexia International member firm Nexia TS (Shanghai) discuss China's latest attempts to implement countrywide standard practices for application of the general anti-avoidance rules, while bringing clarity to foreign entities which are affected.

  • Swiss court challenges fundamental OECD tax principle

    May 27, 2015

    The OECD has updated the commentaries on the Model Tax Convention (Commentaries) seeking to clarify the concept of beneficial ownership in tax treaties. Charles Hermann, a financial services tax partner at KPMG, explores beneficial ownership issues arising from the ‘Swiss Swap’ case.

  • India's MAT: The government is listening

    May 27, 2015

    Poonam Khaira Sidhu, commissioner and departmental representative at the Income Tax Appellate Tribunal (ITAT), New Delhi, talks about open dialogue between authorities and taxpayers, and the evidence that the Indian government is listening to investor concerns.

  • Russia: Revised CFC rules for trusts and foundations

    May 27, 2015

    Half a year after the initial version of the ‘deoffshorisation’ law came into effect, and the Russian Finance Ministry is making progress with vital amendments to make the rules more balanced and clear, including the much-awaited rules on ‘good’ and ‘bad’ trusts. Artem Toropov of Goltsblat BLP explains how private clients are expected to benefit from this.

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International Correspondents

After the Irish budget, what would make you more likely to put more substance into Ireland?