Direct Tax

Archive: Direct Tax

This content is from: China

MNEs should restructure to enjoy China’s beneficial ownership tax treaty rules
By Josh White
April 30 2018
This content is from: United States

Q&A: Ex-Microsoft tax adviser Mike Bernard on data and the digital economy

Mike Bernard, former Microsoft tax counsel, talks to ITR about his experience at Microsoft, how the tax department functioned, and how he will help MNEs use data to be audit-ready in his new role at Vertex.
By Anjana Haines
April 30 2018
This content is from: United Kingdom

Is the UK about to turn against the Big 4?
By Josh White
April 30 2018
This content is from: United States

Goldman Sachs invests in Argentina after Macri’s tax reform
By Josh White
April 30 2018
This content is from: European Union

The race to tax the digital economy

The OECD is seeking a global consensus to tax online companies like Facebook, Google, Microsoft and Amazon, but the European Commission (EC) wants a quick fix while negotiations for a global plan take place. How do th...
By Josh White
April 30 2018
This content is from: United States

The Brockman brief: Legal entity simplification: the time is now

As the US has tried to ‘level the playing field’ with the Tax Cuts and Jobs Act enacted in December 2017, coupled with additional complexities and subjective interpretations around the world, it is time to reflect upo...
By Keith Brockman
April 30 2018
This content is from: Sponsored

New Zealand: Court of Appeal considers double tax relief article in DTA with China

The New Zealand Court of Appeal has overturned a High Court decision allowing a New Zealand taxpayer foreign tax credits for tax spared (under Chinese law) to Chinese companies treated as controlled foreign companies ...
By Brendan Brown

& Matt Woolley

& Russell McVeagh
April 30 2018
This content is from: Global

Plenty on planners’ plates: Tax Planning Survey 2018

The US Tax Cuts and Jobs Act and other countries’ responses to it, the BEPS project, various exchange of information agreements, incoming tax treaty changes and national elections are just a few of the obstacles ensur...
By Joe Stanley-Smith
April 30 2018
This content is from: United States

Americas: US tax reform overturns the old order

US tax reform has raised new challenges for investors looking to manage their tax liabilities. Josh White looks at how the landmark reforms have influenced tax planning across the Americas.
By Josh White
April 30 2018
This content is from: United States

US tax reform: the pitfalls of Section 965 on foreign earnings

The Internal Revenue Service (IRS) has left many questions unanswered about the impact of Section 965 on foreign earnings with Notice 2018-26.
By Josh White
April 30 2018
This content is from: United States

Americas Tax Awards 2018: Enter now

The submissions period for this year’s Americas Tax Awards is open. Private-practice firms, in-house companies and individual tax professionals can win.
By Anjana Haines
April 27 2018
This content is from: European Union

New circular on German treaty shopping rules following ECJ dispute

Following the ECJ ruling in the Deister Holding and Juhler Holding joined cases, the German financial authorities have published a circular invalidating a section of the German Income Tax Act effective from 2007-2011,...
By Joe Stanley-Smith
April 27 2018
This content is from: European Union

Will the EU raise the bar for protecting whistleblowers?

LuxLeaks whistleblower Antoine Deltour has told International Tax Review why he thinks the European Commission’s proposal to strengthen protections for whistleblowers across the EU may not get enacted.
By Josh White
April 27 2018
This content is from: Austria

How the ATAD is pushing Austrian business to restructure

Austria plans to implement CFC rules for the first time to align with the EU’s Anti-Tax Avoidance Directive (ATAD) that enters into force on January 1 2019. But companies may have to swiftly dispose of their holding s...
By Josh White
April 25 2018
This content is from: Austria

Taxing the digital economy: EU Commission Directive proposal for a significant digital ...

The EU Commission’s proposal for a 'significant digital presence' tax is a bold attempt to ring-fence the digital economy, despite the views of some OECD members that this approach is inappropriate.
By Contributed
April 23 2018
This content is from: United States

Raising capital from Mexican pension funds

In recent years, Mexican government agencies, including the Mexican Banking and Securities Commission (CNBV) and the National Retirement Savings System Commission (CONSAR) have implemented regulatory changes with the ...
By ITR Correspondent
April 13 2018
This content is from: United Kingdom

HMRC could extend its ‘shoot first’ APN regime

UK revenue authority HMRC has launched a consultation looking at how to tackle tax avoidance. This consultation proposes using targeted measures to ensure the suspects in such cases pay back the disputed tax even befo...
By Josh White
April 12 2018
This content is from: Singapore

Singapore transfer pricing regulations: Prepare for synchronisation with global best pr...

Multinational enterprises (MNEs) must stay on their toes to deal with numerous changes in Singapore’s tax and transfer pricing regulatory framework enacted in the last year, as well as those still to come.
By Contributed
April 10 2018
This content is from: United States

The case against the robot tax

Taxing corporate income generated through the use of robots may be a popular idea, but the difficulty of drawing a link between the use of artificial intelligence (AI) and corporate income could create a new avenue fo...
By Josh White
April 05 2018

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