This content is from: European Union Enhanced accounting standards could curb investor tax frustrations Companies are starting to explore whether the UK Corporate Accountability Network’s latest accountancy framework - which requires tax data to be included in financial accounts for investor analysis - benefits their ta... By Danish Mehboob July 29 2019
This content is from: Direct Tax Americas Tax Awards 2019: Nominees announced The nominees for the 14th annual Americas Tax Awards have been announced. By Anjana Haines July 25 2019
This content is from: United Kingdom UK gets a new PM and no tax certainty Following Boris Johnson’s win in the Conservative leadership election British businesses have few assurances about the future of UK tax policy and the impact of Brexit. By Josh White July 23 2019
This content is from: Direct Tax G7 leaders push ahead with global minimum tax The finance ministers of the G7 countries have agreed that a global minimum tax should be introduced to ensure companies like Facebook and Amazon pay ‘their fair share of tax’. By Danish Mehboob July 19 2019
This content is from: European Union Survey results: Untangling CFC structures Multinational businesses are simplifying structures to navigate the rules that target controlled foreign corporations (CFCs) and their shareholders. ITR asked those tax heads who have adopted this approach to share th... By Danish Mehboob July 15 2019
This content is from: Switzerland ‘Absolutely shocking’: Corporates shaken after Swiss Supreme Court ignores tax ruling Taxpayers are worried about tax certainty in Switzerland after the Federal Supreme Court ignored an advanced tax ruling in June. This could set a precedent for other cases. By Danish Mehboob July 12 2019
This content is from: Sponsored Italy addresses double taxation arising from foreign TP adjustments Italy has recently implemented a new procedure to mitigate double taxation arising from foreign transfer pricing adjustments. Chiomenti’s Raul-Angelo Papotti, Paolo Giacometti and Andrea Alcara discuss the procedure, ... By ITR Correspondent July 11 2019
This content is from: Sponsored Russia’s 20-year evolution of transfer pricing practices In twenty short years, Russia has undergone a rapid transformation in transfer pricing (TP) adoption and harmonisation with the OECD’s norms. EY CIS’s Evgenia Veter traces the nation’s adoption, evolution and future d... By Evgenia Veter July 11 2019
This content is from: Sponsored Transfer pricing controversy and governance challenges in Luxembourg Luxembourg’s stability and innovative culture has made it a global leader in the financial services sector. However, the greater interaction between the tax and regulatory dimension is creating complex tax governance ... By Deloitte Luxembourg & Enrique Marchesi-Herce & Ralf Heussner July 11 2019
This content is from: Sponsored Germany: Relocations of functions and adjustment payments Germany has been an early indicator of how the OECD’s rules on so-called ‘hard-to-value intangibles’ may look when implemented at the national level. By Nera & Philip de Homont & Yves Hervé July 10 2019
This content is from: Direct Tax How concerned should companies be about data they send to tax authorities becoming public? It’s interesting that the subject of data submitted to the tax authorities becoming public, either through a data leak or public country-by-country reporting (CbCR), is clearly still a significant concern among tax di... By Contributed July 10 2019
This content is from: United Kingdom UK tax transparent funds: Five years on from the first launch Five years after the launch of the first UK authorised contractual scheme (ACS) – also known as the UK tax transparent fund (UK TTF) – in 2014, there are 22 UK TTFs in the market, with 172 sub-funds amounting to billi... By Contributed July 10 2019
This content is from: European Union Taxpayers confident UK will follow EU state aid rules in no-deal Brexit Taxpayers expect the UK to remain aligned with EU state aid rules in the event of a no-deal Brexit, but many hope any potential future amendments will not stifle investments in UK businesses or negatively impact state... By Danish Mehboob July 10 2019
This content is from: Direct Tax Only one way out: Simplifying CFC regimes The number of countries adopting controlled foreign corporation (CFC) regimes has complicated business operations and forced them to change. Danish Mehboob talks to taxpayers who are trying to avoid getting lost in th... By Danish Mehboob July 10 2019
This content is from: Sponsored Tax Advisory Survey 2019 Tax and trade wars among governments and the battles companies face against tax authorities through audits and inevitable disputes mean even the most super-human tax director among us needs a little help. By Anjana Haines July 10 2019
This content is from: Direct Tax Global minimum taxation: A matter of time Minimum tax red flags have appeared in recent legislation as countries and organisations race to address perceived inequities within the international tax regime. By Keith Brockman July 10 2019
This content is from: Sponsored Switzerland: Swiss corporate tax reform bill to apply from 2020 Swiss voters approved the Swiss tax reform and AHV Financing Bill. With headline tax rates of 12%-14% in most cantons, which can be reduced to as low as 9% with instruments such as the patent box, Switzerland will rem... By Deloitte Switzerland & Jacques Kistler & René Zulauf July 10 2019
This content is from: Sponsored Tax transformation: What companies need to know In a wide-ranging interview, ITR speaks to Terri LaRae, partner and leader of the global operations transformation tax team at Deloitte, about the factors driving tax transformation and how tax departments can get the... By Deloitte US July 10 2019
This content is from: European Union Qualified majority voting will drive reforms, says EC’s tax chief The European Commission head of company taxation initiatives has told International Tax Review about his hopes and frustrations in EU corporate tax and why he supports qualified majority voting. By Alexander Hartley July 10 2019
This content is from: Algeria How global tax reforms apply to the extractive industries Alexandra Readhead investigates whether IMF and OECD proposals on how to tax the digital economy, apply formulary apportionment, shift taxing rights and address profit shifting could apply to the natural resources sec... By Contributor July 10 2019
This content is from: Sponsored Romania: EC pushes Romania to revise statute of limitation on customs debts Four months after the European Commission (EC) requested Romania to lower its statute of limitation for additional customs liabilities from five years to three years, we have not identified any action from the Romania... By EY Romania July 10 2019
This content is from: Sponsored Mexico: The decree to end all tax pardon decrees Although this title may read like the like a title to a thriller novel or at least a pretty good campaign soundbite, it comes very close to the actual name of a recently published executive decree in Mexico. By Deloitte Mexico July 10 2019
This content is from: United States Businesses disappointed with OECD’s digital tax progress As G20 countries ratify the OECD’s work on taxing the digital economy, tax executives expressed their concern to International Tax Review that the body has not moved beyond proposals that they find problematic. By Alexander Hartley July 10 2019
This content is from: Sponsored Indonesia exempts taxpayers from late submission penalties The government has issued Director General of Tax Decision No. KEP-440/PJ/2019, concerning the exemption from administrative penalties for the late submission of tax returns (SPT) that were due on April 30 2019. By Dwipa Abimanyu Dewantara & Endy Arya Yoga & GNV Consulting July 10 2019
This content is from: United States The negative aspects of ICAP While feedback on the International Compliance Assurance Programme (ICAP) has been overwhelmingly positive, unsurprisingly, the first pilot did encounter some teething problems. By Joe Stanley-Smith July 10 2019
This content is from: Austria European Tax Awards 2019: The winners The winners of International Tax Review’s 15th European Tax Awards have been announced. By Dan Barabas July 10 2019
This content is from: Cyprus Residence-by-investment schemes continue to create tax loopholes A joint investigation by International Tax Review and Practice Insight has uncovered evidence of tax reporting gaps in the way the OECD's Common Reporting Standard (CRS) applies to international securities markets. By Danish Mehboob July 10 2019
This content is from: United States Case study: Shell’s participation in ICAP Danny Houben, project lead for Shell’s ICAP team, talks to International Tax Review about how his company got ready to participate in the OECD’s International Compliance Assurance Programme (ICAP). By Joe Stanley-Smith July 10 2019
This content is from: Sponsored India: Demystification of scope for claiming tax treaty benefits – welcome stride for f... The Bombay High Court (the High Court) has delivered a landmark precedent while disposing the writ petition filed by a Mauritian company (the petitioner). By Abhishek Mundada & Dhruva Advisors & Sandeep Bhalla July 10 2019
This content is from: Sponsored Italy: Undisclosed dependent agent PE in Italy: Trends and operational impacts In recent years multinational groups have, sensibly, modified their business models to keep up with globalisation and safeguard their competitiveness. By Barbara Scampuddu & Gian Luca Nieddu & Hager & Partners July 10 2019
This content is from: United States Tax heads encourage more companies to use ICAP Tax leaders from Barilla, Repsol and Shell have encouraged their contemporaries to sign up for the International Compliance Assurance Programme (ICAP), before the window to get involved closes later this month. By Joe Stanley-Smith July 10 2019
This content is from: Sponsored Argentina: New tax promotional regime for knowledge-based activities Multinationals in Argentina may want to rethink the way they operate in the country to take advantage of tax benefits available from 2020 under the new tax promotional regime for the so-called knowledge-based economy. By Ignacio Rodríguez & PwC Argentina July 10 2019
This content is from: Sponsored Malta: Malta publishes tax grouping rules The recently published Consolidated Group (Income Tax) Rules, 2019, grant groups, as defined therein, the option to be treated as a single ‘fiscal unit’ for income tax purposes. By Fenech & Fenech Advocates & Rosanne Bonnici July 10 2019
This content is from: United States US companies fear TCJA amendments by Democrats Some US taxpayers are considering inversions because they fear negative tax implications if the Democrats gain control of the presidency and Congress in the 2020 elections and raise the corporate tax rate. By Danish Mehboob July 10 2019
This content is from: United States Case study: Repsol’s participation in ICAP Rocío Bermúdez, tax global practices & transfer pricing senior manager at Repsol, spoke to ITR about her company’s participation in the first pilot of the International Compliance Assurance Programme. By Joe Stanley-Smith July 10 2019
This content is from: Sponsored US: Sale of a partnership interest: Withholding tax The US Treasury and the Internal Revenue Service (IRS) have proposed withholding tax regulations regarding the Tax Cuts and Jobs Act (TCJA) provisions, addressing sales of interests in partnerships engaged in the cond... By David Forst & Fenwick & West & Jim Fuller July 10 2019
This content is from: Europe OECD won’t rush ICAP expansion despite scheme’s popularity The OECD’s Achim Pross says his ultimate aim is to expand the International Compliance Assurance Programme (ICAP), but companies may be disappointed to learn that it could be a relatively slow process. By Joe Stanley-Smith July 10 2019
This content is from: Sponsored Israel: Tax authorities provide certainty on foreign fund investments The stake of foreign investment in the Israeli high-tech industry reached 77% of total capital raised in 2018, and 30 new venture funds were born in 2018, raising a record $2.6 billion compared to ‘only’ $1.6 billion ... By Henriette Fuchs & Pearl Cohen Zedek Latzer Baratz July 10 2019
This content is from: India India’s angel tax Generally, income taxes are not levied at the same time as the investment transaction in the share capital of any company because this amounts to the allotment of new shares. However, writes Anand Jaiswal of Infosys, ... By Contributed July 10 2019
This content is from: Sponsored Luxembourg: Luxembourg adopts exit tax rules aligned with ATAD 1 The Luxembourg Parliament transposed the EU Anti-Tax Avoidance Directive 1 (ATAD 1) into Luxembourg legislation on December 21 2018 By Christophe De Sutter & Deloitte Luxembourg & Thibaut Barras July 10 2019
This content is from: Sponsored Greece: Greece adopts EU ATAD I In April 2019, Greece transposed the EU Council Directive 2016/1164, laying down rules against tax avoidance practices that directly affect the functioning of the internal market (Anti-Tax Avoidance Directive I, or AT... By Constantina Nicolaou & EY in Greece July 10 2019
This content is from: Direct Tax Action 1 and the virtual permanent establishment Antonio Lanotte explores the BEPS Action 1 report and its influence on modern legislation including the UK’s diverted profits tax and India’s proposals for taxing the digital economy. By Contributed July 09 2019
This content is from: European Union DAC6 fixes tax loopholes but confuses taxpayers Banks are confused about how to follow the ‘vague hallmarks’ in the EU mandatory disclosure regime (DAC6). By Danish Mehboob July 08 2019
This content is from: United Kingdom IR35 rules for private sector: Businesses preparing, costs unclear The next part of the UK’s IR35 regulation, which comes into force from April 2020 and is designed to align tax and national insurance (NI) contributions between employees and contractors will cover the private sector. By Contributed July 08 2019
This content is from: United States Silicon Valley’s leading women in tax tackle ‘world peace’ Finding a solution to taxing the digital economy and getting international agreement could win the OECD the tax equivalent of the Nobel Peace Prize, but thankfully being a female tax leader is easier to achieve, accor... By Anjana Haines July 05 2019
This content is from: Portugal Portugal implements ATAD Francisco Cabral Matos and Rita Pereira de Abreu of Vieira de Almeida & Associados explain how the EU Anti-Tax Avoidance Directive (ATAD) is being implemented in Portugal. By Francisco Cabral Matos & Rita Pereira Abreu & Vieira de Almeida July 04 2019
This content is from: Facebook ups the ante for global cryptocurrency tax framework The launch of Facebook’s Libra currency and discussions at the G20 Summit about financial fraud and tax evasion with digital assets has ‘lit a fire under policymakers’ to develop better regulatory responses. By Danish Mehboob July 03 2019
