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Corporate Tax

Corporate Tax archive
  • 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.

  • Collections delayed on transfer pricing bills under India-UK DTAA

    May 25, 2015

    The Indian Ministry of Finance has issued a fresh notice preventing the collection of taxes on transfer pricing cases for Indian subsidiaries of UK resident companies undergoing a mutual agreement procedure (MAP).

  • European Tax Awards 2015 - the winners

    May 22, 2015

    The European Tax Awards 2015 were presented last night at a dinner at the Grosvenor House Hotel in London.

  • Americas Awards 2015: Entry forms are available now

    May 20, 2015

    This year's Americas Tax Awards will take place in New York on September 17. Make sure you are ready to compete.

  • Finance minister: No corporate tax cuts for Indonesia

    May 20, 2015

    The Indonesian Minister of Finance has rejected claims that the country’s corporate tax rate will be cut to less than 18%.

  • Jaitley orders tax authorities to stop issuing MAT bills

    May 15, 2015

    India’s Finance Minister Arun Jaitley has told the tax authorities not to send out any new bills for minimum alternate tax (MAT) to foreign portfolio investors while a committee he has created enquires into the controversy.

  • OECD tax chief highlights benefits and risks of transparency

    May 15, 2015

    Pascal Saint-Amans has emphasised the urgency of fixing the flaws in the international tax system.

  • Possible corporate tax cut faces hurdles in Indonesia

    May 14, 2015

    President Widodo is considering slashing Indonesia's corporate tax rate from 25% to under 18% to stop multinationals transferring profits out of the country to offshore low tax jurisdictions, Luhut Panjaitan, his chief of staff, has said. However, not everyone is convinced the plan will see fruition.

  • Budget confirms Australian commitment to tougher anti-avoidance measures

    May 13, 2015

    Australian Treasurer Joe Hockey had plenty to say about large companies and their tax arrangements in his annual budget statement on May 12.

  • Puerto Rico drops VAT plans; higher taxes on multinationals likely to compensate

    May 13, 2015

    Puerto Rico’s parliament has voted down plans to introduce a VAT of 16%, leading to fears that the government could impose higher taxes on large multinationals, defined as those generating more than $600 million in sales, to plug the territory’s budget deficit.

  • Vestager delays verdict on EC state aid investigations in to Apple, Amazon, Starbucks and Fiat

    May 13, 2015

    The European Commission (EC) will miss its June deadline to complete state aid investigations into tax rulings for Amazon, Apple, Fiat and Starbucks, competition commissioner Margrethe Vestager has announced.

  • ‘Netflix tax’ and diverted profits expected to feature in Australian budget

    May 08, 2015

    Though broad-based tax reform will wait until after a white paper is published later this year, tax professionals expect Australia’s May 12 Budget to continue to lay the foundation for furthering the OECD BEPS initiative, including discussions on controversial taxes on diverted profits and e-commerce sales.

  • Ola Nicolai Borge joins Baker & McKenzie Myanmar

    May 08, 2015

    Ola Nicolai Borge leaves Grant Thornton to join Baker & McKenzie in Yangon.

  • Lam leaves Goldman Sachs after more than a decade

    May 07, 2015

    Jocelyn Lam is finishing up this week at Goldman Sachs before joining KPMG on July 1.

  • BHP Billiton faces $432 million tax bill in Australia

    May 06, 2015

    The Australian Tax Office has challenged the transfer pricing practices of BHP Billiton, serving the country’s largest taxpayer with a A$522 million ($432 million) tax bill, based on the pricing of goods it sold to a marketing affiliate in Singapore. The company’s Singapore tax bill is also being questioned under Australia’s controlled foreign company (CFC) rules, which require a minimum payment of tax.

  • Investors challenge Indian MAT

    May 04, 2015

    Several foreign portfolio investors have banded together to challenge India's minimum alternate tax (MAT) on capital gains in a case that will have wide-reaching implications for investors who face hefty tax bills between 2009 and 2015.

  • Tax deductibility of recharges by non-resident companies in Nigeria under turnover assessment

    May 03, 2015

    For Nigerian tax purposes recharges can be defined as costs reimbursed by a non-resident company to its Nigerian affiliate in respect of services provided by the affiliate in execution of a joint contract in Nigeria. Generally, this amount includes a profit mark-up for the affiliate, and the non-resident company is allowed the amount as a deduction in its income tax returns.

  • How hundreds of multinationals are preparing for BEPS legislation and what you can do

    April 30, 2015

    BEPS is a significant landmark for multinational companies and international revenue organisations. It will mean big changes to companies’ tax and transfer pricing operations. And, while no one knows specifically how the new measure will impact them, taxpayers are trying to prepare.

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International Tax Review Profile

@EvanHD @BBCNewsnight Your point about #northsouth divide in global institutions has echoes in current #internationaltax reform debate too

May 29 2015 09:53 ·  reply ·  retweet ·  favourite
International Tax Review Profile

RT @Alessan11490533: Clifford Chance is the "Italy Tax Firm of the Year" #ITRawards2015 Awarded by @IntlTaxReview. http://t.co/ISTGWVRc5b

May 29 2015 09:49 ·  reply ·  retweet ·  favourite
International Tax Review Profile

RT @OticoSoftware: @IntlTaxReview Otico Software #BEPS and #CBCR transfer pricing software just launched http://t.co/PhYDvCCmFe

May 29 2015 09:49 ·  reply ·  retweet ·  favourite
International Tax Review Profile

RT @BMRAdvisors: @mukeshbutani shared views in the panel discussion 'Anti-abuse provisions & tax litigation' today at #TaxandConf in #Milan…

May 28 2015 12:36 ·  reply ·  retweet ·  favourite
International Tax Review Profile

RT @EYnews: EY wins 9 awards at @IntlTaxReview European Awards 2015, including European #Tax Compliance & Reporting Firm of the Year

May 28 2015 12:34 ·  reply ·  retweet ·  favourite
International Correspondents

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