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  • Building your BRICS tax strategy

    How to organise your tax affairs across the BRICS nations.

  • The future for BRICS tax policy coordination

    The BRICS members are important players on the world’s economic stage and are working more closely together in this sense. But tax policy remains primarily the preserve of individual nations. Salman Shaheen looks at tax policy priorities for the BRICS and the areas in which they should work more closely together in the future.

  • Practical transfer pricing in the BRICS

    The BRICS represent five significant transfer pricing jurisdictions for taxpayers. All of them are big investment targets but each of them has a different transfer pricing regime to adhere to. Litigation is on the up in all of them. Sophie Ashley provides an overview of the trends and pitfalls taxpayers are facing in the BRICS and how to get around them.

  • Structuring your tax affairs in the BRICS

    When Goldman Sachs economist Jim O’Neill coined the BRIC acronym in 2001, his new term was born out of a desire to group together those countries viewed as emerging growth markets. The grouping worked because it was clear these countries shared common features, which marked them apart from the rest of the world. That being the case, it is no surprise that the tax structures employed in these countries often need to be different from those used elsewhere. Matthew Gilleard talks to taxpayers and advisers about such structures, what the common mistakes are, and what taxpayers can and cannot do, as compared to tax rules elsewhere.

  • A foreign investor’s tax guide to the CIVETs

    Joe Dalton examines the tax regimes of the CIVETs countries to discover whether they truly constitute attractive and secure future investment destinations for multinationals, or if the term is simply another economist’s efforts to jump on the acronym bandwagon.


Features

  • Africa: M&A challenges faced by foreign investors

    Francisco Almada and Ekow Eghan of Ernst & Young’s transaction tax team go through the key M&A challenges faced by foreign investors in Africa.

  • Spain hikes taxes to battle downturn

    In an effort to raise tax revenues and reduce the budget deficit, in the past 12 months the Spanish government has introduced several far-reaching tax measures, affecting virtually all the taxes applicable to large businesses or individuals. Vicente Bootello and Álvaro de la Cueva of Garrigues analyse the changes.

  • No waiting – FFIs should act now to prepare for FATCA

    The publication of potential options for implementation of Foreign Account Tax Compliance Act makes it even more important for taxpayers to ensure they know about the legislation, warn Thomas Humphreys, Remmelt Reigersman and Jared Goldberger of Morrison & Foerster.

  • Australia to reform its general anti-avoidance regime

    After a series of court losses suffered by the Commissioner of Taxation, Australia's general anti-avoidance regime (GAAR), part IVA, looks set to undergo a significant modification to its scope and application. Mark Friezer and John Boyagi of Clayton Utz explore the reasons motivating the reform and why taxpayers need to keep track of the changes.

  • The UK GAAR: What needs answering

    The general anti-avoidance rule (GAAR) is set to become the UK tax authorities’ latest tool for targeting and counteracting tax avoidance. Sandy Bhogal and Ben Fryer of Mayer Brown analyse the consultation, and assess how such a rule will affect taxpayers.

  • FATCA – How ready are you?

    Tom Walsh, managing director, global customs trade and trust, for the tax & accounting business of Thomson Reuters, explains why there is a lack of confidence among firms that implementation deadline can be met.

  • Canada – US arbitration: Too soon to pass judgment

    Brad Rolph of Charles River Associates in Canada takes a closer look at the memorandum of understanding (MOU) on arbitration between the US and Canada and the accompanying arbitration board operating guidelines. He also examines whether the arbitration procedure is accomplishing its objectives to reduce the amount of time it takes to resolve double taxation cases and increase the use of principle-based negotiating positions.

  • Analysing the OECD draft on intangibles

    Issues involving intangibles likely account for the majority of transfer pricing disputes, by dollar volume, in most major countries throughout the tax world. This trend is expected to continue in future years. Todd Wolosoff and David Cordova of Deloitte Tax discuss the OECD’s recent draft on the transfer pricing aspects of intangible assets.

  • Myanmar’s tax on non-residents on the eve of a leap in FDI

    The lifting of US sanctions on general investment in Myanmar is one of the key indications that this Southeast Asian frontier market is poised for a big leap in terms of foreign direct investment (FDI). Cynthia Herman, Edwin Vanderbruggen and Thida Cho Win of VDB Loi discuss how non-residents will be taxed.

  • Navigating India’s proposed GAAR

    Proposed Indian general anti-avoidance rules (GAAR) were not met with much support when details were revealed earlier this year. But a recent consultation period has brought transparency and clarity to proposal, much to the benefit of taxpayers explains Rajendra Nayak of Ernst & Young.

  • Increased focus on tax governance

    Mak Oi Leng of KPMG in Singapore explains why corporate stakeholders such as boards of directors, tax directors, chief executive officers and chief finance officers should all have a vested interest in their company’s tax governance.

  • Transfer pricing investigation versus self-inspection

    As transfer pricing enforcement evolves, the State Administration of Taxation (SAT) in China has developed the concept of anti-avoidance tax system combining management, service and investigation. Wu Duo and Li Ying of Siemens in China discuss the merits of transfer pricing investigation versus self-inspection.

  • The future of indirect taxes in Japan

    Kotaku Kimu of PwC looks at Japan’s carbon tax, the doubling of consumption tax and what these reforms mean for taxpayers.

  • Outsourcing – A solution to VAT compliance challenges

    Abhishek Shah of Ernst & Young looks at the benefits of outsourcing VAT compliance, what to look for when outsourcing to an accountancy firm and tips for doing it successfully.

  • Taxation of corporate debt in Ireland versus the UK

    While the banking crisis in Ireland has constricted traditional lines of credit, it has also created opportunities for financial institutions with healthier balance sheets to finance the many businesses based in Ireland with strong fundamentals. Understanding the tax implications for the Irish borrower is a key consideration in the lending process. John Gulliver and David Burke of Mason Hayes & Curran examine the tax treatment of corporate debt for Irish borrowers, comparing and contrasting this by way of illustration with the tax treatment for UK borrowers.

  • Beneficial ownership of Danish deemed dividend distributions

    Danish taxpayers should be able to avoid withholding tax on certain reorganisations after the National Board delivered a ruling on deemed dividend distributions, argue Anders Oreby Hansen, Poul Erik Lytken and Arne Riis of Bech Bruun–Taxand.

  • Opinion in FII litigation fails to answer all questions

    The claimants and other tax professionals are waiting for the European Court’s judgment in the FII Group Litigation to see if it will add clarity to issues about different levels of taxation and third countries, says Philippe Freund of Dorsey & Whitney.

  • Poland challenges related entity transactions

    Poland’s Supreme Court recently questioned the economic rationale behind the acquisition of procurement services from a related entity. Aneta Blazejewska-Gaczynska of Ernst & Young explains why this decision should force multinationals to examine their supply chain structures.

  • Introduction of new measures to tackle VAT fraud

    VAT fraud costs the EU and the national budgets several billion euros every year. Thus, avoiding fraud has become the most important issue for the EU and the member states. Ronny Langer and Thomas Küffner of Küffner Maunz Langer Zugmaier look at the measures that have been introduced to address the problem and how they are affecting honest businesses.


News Analysis



Editorial


Tax Relief


International Correspondents


International Tax Review Profile

RT @BrigitteAlepin: So proud of the new book WINNING THE TAX WARS. Bringing together well-known tax experts, this book presents outstanding…

Dec 7 2017 04:08 ·  reply ·  retweet ·  favourite
International Tax Review Profile

REVEALED: The top 10 of ITR's #GlobalTax50 2017 is out now. Find it here: https://t.co/IXiaRrE3vH (subscription or free trial required)

Dec 7 2017 01:42 ·  reply ·  retweet ·  favourite
International Tax Review Profile

ITR has opened the submissions period for the European Tax Awards 2018. Full details here: https://t.co/WKBWijhBgt

Dec 6 2017 01:40 ·  reply ·  retweet ·  favourite
International Tax Review Profile

@aloysrigaut @AuroChardon @ElodieLamer @JeanComte @diego_bxl @bsmithmey @afpfr @pierremoscovici @EU_Taxud @EU2017EE… https://t.co/oS4sDvQtdL

Dec 5 2017 04:55 ·  reply ·  retweet ·  favourite
International Tax Review Profile

RT @AuroChardon: Is this it? https://t.co/O1XhoWQw2F 17 #taxhavens, mostly tiny countries or emerging economies on the #EUblacklist? ❌Swit…

Dec 5 2017 02:25 ·  reply ·  retweet ·  favourite
International Correspondents