Direct Tax

Archive: Direct Tax

This content is from: European Union

EU action safeguards OECD global tax reform

The European Parliament advanced a resolution on December 18 to adopt an EU standard to tax digital companies in case the OECD fails to find consensus on its global approach.
By Danish Mehboob
December 19 2019
This content is from: United Kingdom

Inaccuracies in HMRC’s revised IR35 CEST tool risks litigation

Tax barristers have warned that HMRC’s check employment status for tax (CEST) tool is inconsistent with tribunal decisions and companies should use a range of resources to protect their workforce assessments.
By Danish Mehboob
December 19 2019
This content is from: Sponsored

The MLI: Minimum standards and Luxembourg’s choices

Christophe De Sutter and Giedre Tamai of Deloitte Tax & Consulting explain the minimum standards of the pioneering MLI and unravel what the changes mean for Luxembourg.
By Christophe De Sutter

& Deloitte Luxembourg

& Giedre Tamai
December 18 2019
This content is from: Market Insight

Euromoney Legal Media Group Asia Women in Business Law Awards 2019: Winners announced

Euromoney Legal Media Group has announced the results of the ninth annual Asia Women in Business Law Awards 2019, celebrating the best women lawyers as well as best firms for women in the law from across the region.
By Anjana Haines
December 18 2019
This content is from: Sponsored

Italian tax authorities continue to question entrepreneurial behaviour

Gian Luca Nieddu and Barbara Scampuddu of Hager & Partners discuss how tax authorities in Italy continue to try and keep close tabs on the behaviour of entrepreneurs by leveraging anti-avoidance rules.
By Barbara Scampuddu

& Gian Luca Nieddu

& Hager & Partners
December 17 2019
This content is from: Sponsored

US Inbound: Treasury and IRS revoke §385 Documentation Regulations and will revise Dist...

David Forst and James Fuller of Fenwick & West discuss the recent changes which modify the exisiting Section 385 regulations.
By David Forst

& Fenwick & West

& Jim Fuller
December 17 2019
This content is from: Sponsored

Spain: A quest to locate risk for insurance premium tax

Jorge Moreira Pelaez of Garrigues investigates a potential flaw in how insurance transactions are located, which could lead insurance and reinsurance taxpayers onto difficult territory.
By Garrigues Spain

& Jorge Moreira Pelaez
December 17 2019
This content is from: Sponsored

Russia: Russia’s participation exemption: A clarification

A brief update to Nuances embedded in Russia’s participation exemption (ITR, January 29 2019) by Viktoria Ivashchenko, Denis Gamiy and Dmitry Garaev of KPMG.
By Denis Gamiy

& Dmitry Garaev

& KPMG Russia
December 17 2019
This content is from: Sponsored

New Zealand: Inland Revenue updates its multinational enterprises compliance focus

Brendan Brown and Matt Woolley of Russell McVeagh assess the impact of Inland Revenue’s latest update to its Multinational Enterprises Compliance Focus document.
By Brendan Brown

& Matt Woolley
December 17 2019
This content is from: Sponsored

Malta: Patent box regime launched

Rebecca Diacono of Fenech and Fenech Advocates outlines conditions and benefits as Malta introduces new rules to create incentives for qualifying taxpayers.
By Fenech & Fenech Advocates

& Rebecca Diacono
December 17 2019
This content is from: Sponsored

Hong Kong: Hong Kong SAR’s long-standing practice on foreign withholding taxes

Lewis Lu and Curtis Ng of KPMG look at changes by Hong Kong SAR’s Inland Revenue Department to its foreign withholding tax treatment that could increase of the cost of doing business for multinational groups
By Curtis Ng

& KPMG Hong Kong

& Lewis Lu
December 17 2019
This content is from: Sponsored

China: China releases DTA guidance to tackle red tape

Lewis Lu of KPMG analyses the tax authorities’ fresh guidance on double tax agreements as the push for bureaucratic streamlining continues.
By KPMG China

& Lewis Lu
December 17 2019
This content is from: Sponsored

Chile: Government and Senate’s Finance Commission agree on a range of tax changes

Mauricio Valenzuela and Santiago Tubio of PwC outline the main amendments put forward by the executive branch to increase Chilean tax efficiency.
By Mauricio Valenzuela

& PwC Chile

& Santiago Tubio
December 17 2019
This content is from: Sponsored

Irish banks lose appeal to resist UK PE capital attribution

The UK Upper Tribunal ruled in favour of HMRC in an appeals case, where two Irish financial institutions tried to overturn a past ruling. Murray Clayson explores the case and its implications.
By Murray Clayson
December 17 2019
This content is from: Italy

Media furore targets Netflix over corporate tax

Despite being compliant with the law, Netflix continues to face harsh criticism for its European tax arrangements. Andrew Parkes, national technical director at Andersen Tax, reviews the company’s trial by media.
By Andrew Parkes
December 17 2019
This content is from: Market Insight

The evolution of tax functions will accelerate in 2020

New rules governing international tax in 2020 underscore the importance of the role of in-house tax as a trusted partner embedded across the business, writes Sandy Markwick, head of the Tax Director Network (TDN) at W...
By Sandy Markwick
December 17 2019
This content is from: Sponsored

What Mexican tax reform means for foreign investors

The Mexican government, under the leadership of President Andrés Manuel López Obrador (AMLO), approved the first major tax reform of its administration, which will take effect on January 1 2020.
By Alfonso Corral M

& Antonio Vite

& Hector Trigos P

& VCG Partners
December 17 2019
This content is from: Global

The organisations leading change

Coupled with the Global Tax 50, Keith Brockman focuses on some of the change-making organisations that have orchestrated significant international tax changes and disrupted age-old tax norms.
By Keith Brockman
December 17 2019
This content is from: Global

Global Tax 50 2019

It is tough to look beyond the discussions taking place on how to tax the digitalisation of the economy, but ITR’s Global Tax 50 attempts to do just this. Anjana Haines introduces the ninth edition of the landmark fea...
By Anjana Haines

& Danish Mehboob

& Josh White

& Mattias Cruz Cano

& Patrick Wiseman
December 17 2019
This content is from: Direct Tax

Global Tax 50 2019: Donald Trump

US President
By Anjana Haines
December 17 2019
This content is from: Direct Tax

Global Tax 50 2019: Tax Justice Network

Independent international network launched to "change the weather" on tax issues
By Patrick Wiseman
December 17 2019
This content is from: Direct Tax

Global Tax 50 2019: Pascal Saint-Amans

Director of the OECD's Centre for Tax Policy and Administration
By Mattias Cruz Cano
December 17 2019
This content is from: Direct Tax

Global Tax 50 2019: Gerard Ryle

Director, International Consortium of Investigative Journalists (ICIJ)
By Mattias Cruz Cano
December 17 2019
This content is from: Direct Tax

Global Tax 50 2019: Achim Pross

Head of the International Co-operation and Tax Administration Division Centre for Tax Policy and Administration
By Anjana Haines
December 17 2019
This content is from: Direct Tax

Global Tax 50 2019: The Oxford International Tax Group

Bringing together economists and lawyers to reconsider the fundamentals of the international tax system and propose more considered reforms
By Patrick Wiseman
December 17 2019
This content is from: Direct Tax

Global Tax 50 2019: Tim McDonald

Vice president of global taxes at Procter & Gamble
By Danish Mehboob
December 17 2019
This content is from: Germany

Global Tax 50 2019: Stefan Greil

Deputy head of international corporate taxation and external tax law, Germany Federal Ministry of Finance, and lecturer in international taxation and post-doctoral fellow at the department of business taxation of the ...
By Anjana Haines
December 17 2019
This content is from: Direct Tax

Global Tax 50 2019: Francois Chadwick

Vice president of finance, tax and accounting, Uber
By Josh White
December 17 2019
This content is from: Sponsored

Mexico implements BEPS Action 4 to limit interest deductibility

The Mexican government has set out to reform the tax system to include the OECD’s recommended limits on interest deductibility in accordance with BEPS Action 4. Mexican tax reform will define 2020.
By Carlos Enrique Naime Haddad

& Chevez Ruiz Zamarripa

& Manuel Alejandro Barron M
December 17 2019
This content is from: Direct Tax

Too many cooks

Everyone wants a slice of the tax pie, but if the pie cannot get any bigger does this mean someone will have to go hungry to feed another?
By Anjana Haines
December 17 2019
This content is from: Direct Tax

Global Tax 50 2019: Logan Wort

Executive Secretary, African Tax Administration Forum (ATAF)
By Anjana Haines
December 17 2019
This content is from: Direct Tax

Global Tax 50 2019: Women in tax

Celebrating women in tax networks globally
By Anjana Haines
December 17 2019
This content is from: Direct Tax

Global Tax 50 2019: Zayda Manatta

Head of the Secretariat of the Global Forum on Transparency and Exchange of Information for Tax Purposes
By Anjana Haines
December 17 2019
This content is from: Sponsored

Switzerland: Doing FATCA group requests right

Brandi Caruso and Robin King of Deloitte investigate the lessons learned and pitfalls to avoid in responding to FATCA group requests under the Swiss-US double tax treaty.
By Brandi Caruso

& Deloitte Switzerland

& Robin King
December 17 2019
This content is from: Sponsored

Indonesia: Tax round-up

Jeklira Tampubolon and Julius Wahyu Daryono of GNV Consulting Services summarise November’s tax-related developments in Indonesia.
By GNV Consulting

& Jeklira Tampubolon

& Julius Wahyu Daryono
December 17 2019
This content is from: Direct Tax

Global Tax 50 2019: Wang Jun

Commissioner of the China State Taxation Administration
By Mattias Cruz Cano
December 17 2019
This content is from: Europe

Global Tax 50 2019: DAC6

The EU’s hard-hitting disclosure rules
By Danish Mehboob
December 17 2019
This content is from: United Kingdom

Global Tax 50 2019: Corporate Accountability Network

Identifying the causes of the accounting crisis and offering solutions
By Danish Mehboob
December 17 2019
This content is from: United States

Global Tax 50 2019: Carol Doran Klein

Vice president and international tax counsel, USCIB
By Patrick Wiseman
December 17 2019
This content is from: United Kingdom

Global Tax 50 2019: Fair Tax Mark

Certification scheme for responsible corporate taxpayers
By Patrick Wiseman
December 17 2019
This content is from: Direct Tax

Global Tax 50 2019: The B Team

Bringing together a group of global leaders from business, civil society and government to catalyse a better way of doing business.
By Danish Mehboob
December 17 2019
This content is from: Canada

Global Tax 50 2019: The Cameco case

One of the most significant transfer pricing cases in Canada
By Mattias Cruz Cano
December 17 2019
This content is from: Direct Tax

Global Tax 50 2019: Grace Blakeley

Research fellow at the Institute for Public Policy Research (IPPR).
By Patrick Wiseman
December 17 2019
This content is from: Direct Tax

Global Tax 50 2019: Keidanren

Japan’s most powerful business association
By Mattias Cruz Cano
December 17 2019
This content is from: Mexico

Global Tax 50 2019: Andrés Manuel López Oprador

President of Mexico
By Mattias Cruz Cano
December 17 2019
This content is from: France

Global Tax 50 2019: Bruno Le Maire

As the OECD attempts to find a solution on how to tax the digitalisation of the economy, its members are becoming frustrated by the lack of progress and taking action unilaterally. One of the most impatient countries ...
By Patrick Wiseman
December 17 2019
This content is from: Global

Global Tax 50 2019: The Inclusive Framework

More than 135 countries and jurisdictions collaborating on BEPS to tackle tax avoidance, improve the coherence of international tax rules and ensure a more transparent tax environment.
By Josh White

& Patrick Wiseman
December 17 2019
This content is from: United States

Global Tax 50 2019: Lafayette ‘Chip’ Harter

Deputy assistant secretary for international tax affairs in the Office of Tax Policy at the US Department of the Treasury
By Danish Mehboob
December 17 2019
This content is from: Direct Tax

Global Tax 50 2019: The G7

International inter-governmental economic organisation consisting of the seven largest IMF-advanced economies: Canada, France, Germany, Italy, Japan, the UK and US.
By Mattias Cruz Cano
December 17 2019
This content is from: Direct Tax

Global Tax 50 2019: Nirmala Sitharaman

India Minister of Finance and Corporate Affairs
By Anjana Haines
December 17 2019
This content is from: Uganda

Global Tax 50 2019: Yuweri Museveni

President of Uganda
By Anjana Haines
December 17 2019
This content is from: Direct Tax

Global Tax 50 2019: Edward Kieswetter

Commissioner of the South African Revenue Service
By Josh White
December 17 2019
This content is from: United Kingdom

Global Tax 50 2019: Boris Johnson

UK Prime Minister
By Josh White
December 17 2019
This content is from: Europe

Global Tax 50 2019: Ursula von der Leyen

President of the European Commission
By Mattias Cruz Cano
December 17 2019
This content is from: United Kingdom

Global Tax 50 2019: Jim Harra

Chief Executive and First Permanent Secretary, HMRC
By Anjana Haines
December 17 2019
This content is from: United Kingdom

Global Tax 50 2019: Jeremy Corbyn

Leader of the UK Labour Party
By Josh White
December 17 2019
This content is from: Direct Tax

Global Tax 50 2019: The Global Reporting Initiative

Independent standard setting body
By Danish Mehboob
December 17 2019
This content is from: European Union

Global Tax 50 2019: Margrethe Vestager

Executive vice president and commissioner for competition, European Commission
By Anjana Haines
December 17 2019
This content is from: Direct Tax

Global Tax 50 2019: USMCA trade deal

United States-Mexico-Canada trade agreement
By Patrick Wiseman
December 17 2019
This content is from: Direct Tax

Global Tax 50 2019: Swiss tax reform

One of the largest changes Switzerland has had to make to its tax system
By Anjana Haines
December 17 2019
This content is from: Direct Tax

Global Tax 50 2019: Supreme Court of India

Highest judicial court under the Constitution of India
By Anjana Haines
December 17 2019
This content is from: Direct Tax

Global Tax 50 2019: Xavier Oberson

Professor in Swiss and international tax law
By Danish Mehboob
December 17 2019
This content is from: Direct Tax

Global Tax 50 2019: The Ninth Circuit Court of Appeals

US Court of Appeal, covering 13 districts and two territories
By Josh White
December 17 2019
This content is from: Indonesia

Global Tax 50 2019: Sri Mulyani Indrawati

Minister of Finance, Indonesia
By Anjana Haines
December 17 2019
This content is from: United States

Global Tax 50 2019: The Green New Deal and the Baker-Shultz proposal

US proposals to tax carbon emissions
By Danish Mehboob
December 17 2019
This content is from: Direct Tax

Global Tax 50 2019: Rutger Bregman

Author
By Patrick Wiseman
December 17 2019
This content is from: Brazil

Global Tax 50 2019: Brazil tax reform

Overhaul of a complicated tax system.
By Danish Mehboob
December 17 2019
This content is from: United Kingdom

Global Tax 50 2019: Accounting scandals

The campaign to split auditing and consultancy firms.
By Josh White
December 17 2019
This content is from: United States

Tax Relief

Because tax doesn’t have to be taxing. A less-than-serious look back at some of the quirkier tax stories from the past month.
By Josh White

& Mattias Cruz Cano
December 17 2019
This content is from: Sponsored

The effects and opportunities of ending a business in Chile

Gregorio Martinez and Fernando Binder of PwC Chile explore the development and advantages of Chile’s unique end of business tax.
By Fernando Binder

& Gregorio Martínez

& PwC Chile
December 16 2019
This content is from: Brazil

MNEs should back the end of Brazil’s income tax exemption on dividends

Multinational corporations must lobby to remove the shareholder income tax exemption that is plaguing Brazil’s regressive tax system. Márcio Calvet Neves sets out the reasons why and how companies would benefit.
By Contributor
December 16 2019
This content is from: United Kingdom

UK election brings short-term tax certainty for businesses

The Conservative government has won a shock majority in the UK election and many British businesses can expect short-term certainty.
By Josh White
December 13 2019
This content is from: Transfer Pricing

Minimum tax rate needs global blending, says FTSE 100 group

The OECD’s pillar two proposal for a global minimum tax rate requires a worldwide blending approach to be enforceable and easy to administer, according to The 100 Group.
By Josh White
December 12 2019
This content is from: Direct Tax

Taxpayers suggest consolidated statement tweaks to fit GloBE rules

Tax professionals widely agree with the OECD on using consolidated financial statements to determine effective tax rates under the pillar two global anti-base erosion (GloBE) proposal.
By Danish Mehboob
December 11 2019
This content is from: Direct Tax

The US supports GloBE, but global taxpayers are hesitant

The OECD’s global anti-base erosion (GloBE) proposal under pillar two is broader than taxpayers expected. It risks over-complicating international tax before the impact of the BEPS project settles in.
By Danish Mehboob
December 06 2019
This content is from: Direct Tax

Japanese businesses seek clarity on new taxing rights

Japanese companies have requested clear and simple approach towards new taxing rights and the consideration of loss-making in the OECD’s pillar one proposals.
By Mattias Cruz Cano
December 05 2019
This content is from: Direct Tax

US-France DST tensions may spark wider EU trade war

The US escalates trade tensions with France after threatening new tariffs following its investigation into the French digital services tax (DST). French officials said the EU is ready to retaliate.
By Danish Mehboob
December 03 2019
This content is from: Sponsored

We need to talk about platforms: Ongoing tax challenges in China

As policymakers in China and elsewhere inch towards a new global tax framework to deal with the challenges of digitalisation, many domestic tax law and administration issues are yet to be resolved for China’s digital ...
By Conrad Turley

& KPMG China

& Sunny Leung
December 03 2019
This content is from: Sponsored

BEPS 2.0: What will it mean for China?

Intensive work at an international level to erect a new architecture for international tax rules by 2020 will have deep implications for businesses. Conrad Turley and Sunny Leung explore what this might mean for China...
By Conrad Turley

& KPMG China

& Sunny Leung
December 03 2019
This content is from: Sponsored

The age of reason(ableness): Economic shifts impact China’s cross-border tax enforcement

In the context of a changing global trade and investment environment, and China’s economic slowdown, tax enforcement approaches are evolving and maturing. Chris Xing and Conrad Turley trace the latest trends.
By Chris Xing

& Conrad Turley

& KPMG China
December 03 2019
This content is from: Sponsored

China double tax arrangements: New paths emerge

The past year has seen a further evolution in China’s tax treaties, in particular in integrating impactful BEPS permanent establishment (PE) changes. The maturity of work on global tax reforms hints at more profound c...
By Chris Xing

& Conrad Turley

& KPMG China
December 03 2019
This content is from: Sponsored

Going out: China outbound investment faces new tax challenges

While global FDI levels sag and China ODI falls, Chinese investment in BRI jurisdictions continues to grow. However, a range of tax challenges face Chinese MNEs in BRI countries and other locations, write Michael Wong...
By Joseph Tam

& KPMG China

& Michael Wong
December 03 2019
This content is from: Sponsored

China capital markets open up: New opportunities bring fresh tax challenges

China’s capital markets continue to expand and open up, offering a range of innovative new investment channels. Henry Wong explores the tax challenges arising under each of these channels.
By Henry Wong

& KPMG China
December 03 2019
This content is from: Sponsored

IIT reform: Paving the future of personal income tax compliance in China

In 2019, the major individual income tax (IIT) reform initiated in 2018 was reinforced with a string of clarifications. Chinese tax residents and foreigners with exposure to Chinese IIT are coming up to speed with the...
By KPMG China

& Michelle Zhou
December 03 2019
This content is from: Sponsored

Offshore economic substance laws: Implications for Hong Kong SAR’s funds sector

The implementation of economic substance laws in offshore jurisdictions will impact funds with management and advisory teams in Hong Kong SAR. Darren Bowdern and Johnson Tee explain how these changes will prompt a rev...
By Darren Bowdern

& Johnson Tee

& KPMG China
December 03 2019
This content is from: Sponsored

R&D tax incentives: Continuous encouragement and enhanced supervision

China has continued to improve access to tax incentives and provide new regulatory support for innovation. At the same time, renewed rigour is being applied to ensure that tax incentives are claimed appropriately. Bin...
By Bin Yang

& KPMG China

& Nicole Cao
December 03 2019
This content is from: Sponsored

No pain no gain: Tax challenges in the China M&A market

This past year has seen heightened inbound M&A activity in hot sectors such as life sciences and logistics, just as the Chinese tax authorities apply more sophisticated enforcement approaches to M&A. Michael Wong, Chr...
By Christopher Mak

& KPMG China

& Michael Wong

& Stella Zhang
December 03 2019
This content is from: Sponsored

Checklist of hot China tax issues for MNEs in 2020

In 2020, taxpayers should be alert for the following China tax developments and trends.
By KPMG China

& Sunny Leung
December 03 2019
This content is from: Sponsored

China Looking Ahead: A changing global environment

This edition of China – Looking Ahead comes at a precarious and symbolically charged time, with the 12-year Chinese zodiac cycle about to end and a new one about to begin. KPMG China’s Head of Tax Lewis Lu highlights ...
By KPMG China

& Lewis Lu
December 03 2019
This content is from: Sponsored

Looking ahead - KPMG's China Special Focus launched

As the Chinese zodiac cycle moves into a new 12-year cycle, the changes across the tax landscape are transitioning in a similar fashion.
By Anjana Haines
December 03 2019
This content is from: Sponsored

Managing China’s wealth: Rich pickings for foreign asset managers

The steady growth of China’s middle class is increasing the demand for asset and wealth management services for domestic institutions and individuals. Henry Wong explores the commercial and tax implications of these d...
By Henry Wong

& KPMG China
December 03 2019
This content is from: Sponsored

Tax administration and compliance management: Steady progress follows reforms

China merged its previously separate state and local tax authority systems in 2018. This has provided a basis for improvements in tax administration and services, and required taxpayers to adapt. Michael Li, Tracey Zh...
By Fang Wei

& KPMG China

& Michael Li

& Tracey Zhang
December 03 2019
This content is from: Sponsored

Bonded zones and free trade agreements: Optimising the trade environment

In 2019, China has pushed reforms to customs supervision and expanded the role of bonded zones, further intensified its use of TP documentation for customs purposes, and sought to refresh key trade agreements. Eric Zh...
By Eric Zhou

& KPMG China

& Rachel Tao
December 03 2019
This content is from: Sponsored

Adapting to a complex world: The evolution of Hong Kong SAR tax

The Hong Kong SAR government has continued its international focus, introducing incentives to boost competitiveness while taking steps to address global tax avoidance, write Curtis Ng and Ivor Morris.
By Curtis Ng

& Ivor Morris

& KPMG China
December 03 2019
This content is from: Sponsored

Mutual Agreement Procedure in Brazil: challenges and contributions

Brazil continues to innovate and lay out plans to tackle its highly litigious and inefficient local tax dispute environment.
By Gil Mendes

& Mattos Filho
December 02 2019
This content is from: Europe

Countries address data mismatches in AEOI at the Global Forum

Government officials found poor quality data from the automatic exchange of information (AEOI) and discussed implementation challenges at the OECD’s Global Forum.
By Danish Mehboob
December 02 2019
This content is from: Global

Corporate transparency without context is simply data open to interpretation

Greater transparency in corporate tax affairs needs to be backed up by effective communication strategies and governance frameworks if businesses are to avoid the risks that come with openness, says Sandy Markwick, he...
By Sandy Markwick
December 02 2019
This content is from: Direct Tax

Japanese companies push for clear OECD definition of ‘consumer-facing businesses’

Japanese companies have called for the OECD to clarify what counts as a ‘consumer-facing business’ in its work on the taxation of the digital economy.
By Mattias Cruz Cano
December 02 2019

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