Direct Tax

Archive: Direct Tax

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Conseil d’Etat rules on French anti-avoidance rules related to low-tax jurisdictions

Nicolas Duboille of Sumerson analyses recent judicial rulings put forward concerning the application of the anti-avoidance rule in France.
By Nicolas Duboille

& Sumerson
August 31 2020
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Considering the assessed value of building plots in Portugal

Rita Magalhães and Bárbara Miragaia of Vieira de Almeida analyse whether the Portuguese tax authorities are unnoticeably doubling the assessed value of properties.
By Bárbara Miragaia

& Rita Magalhães

& Vieira de Almeida
August 28 2020
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Mutual agreement procedure rules transposed into Italian law

Federico Vincenti and Carola Valente of Crowe Valente/Valente Associati GEB Partners discuss how tax dispute settlements in Italy are set to evolve.
By Carola Valente

& Crowe Valente/Valente Associati GEB Partners

& Federico Vincenti
August 28 2020
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A look at why Singapore is a preferred destination in Asia for family offices

Sivakumar Saravan and Liew Kin Meng of Crowe Singapore explore how the country’s favourable investment climate is attractive to ultra-high net worth individuals and families.
By Crowe Singapore

& Liew Kin Meng

& Sivakumar Saravan
August 27 2020
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Draft guidance on non-resident employers' tax obligations for employees in New Zealand

Tim Stewart and Alex Ladyman of Russell McVeagh summarise the draft operational statement released by New Zealand Inland Revenue on non-resident employers' employment-related tax obligations in relation to employees i...
By Alex Ladyman

& Russell McVeagh

& Tim Stewart
August 27 2020
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Looking at China’s integrated circuit and software sector tax incentives

Lewis Lu of KPMG discusses how policymakers have moved to incentivise production in China’s technology sector.
By KPMG China

& Lewis Lu
August 27 2020
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Norwegian parliament ends GAAR discussion regarding pre-transaction reorganisations

Daniel Herde and Oscar Brown of Deloitte present the status of the newly codified general anti-avoidance rule (GAAR) and its applicability on reorganisations in connection with a transaction.
By Daniel Herde

& Deloitte Norway

& Oscar Brown
August 26 2020
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The Italian Supreme Court rules on the definition of beneficial owner

Gian Luca Nieddu and Barbara Scampuddu of Hager & Partners analyse how the Italian courts are interpreting the idea of beneficial ownership and the notion of abuse.
By Barbara Scampuddu

& Gian Luca Nieddu

& Hager & Partners
August 26 2020
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Learning from the Addy and Auctus Resources decisions in Australia

From economic recovery plans to judicial decisions, Paul McNab of DLA Piper summarises the tax-related developments from mid-2020 in Australia.
By DLA Piper Australia

& Paul McNab
August 26 2020
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Indonesia introduces income tax incentives and approves bilateral agreements

Hartiadi Budi Santoso and Reza Farhan of GNV Consulting Services summarise tax-related developments from mid-2020 in Indonesia.
By GNV Consulting

& Hartiadi Budi Santoso

& Reza Farhan
August 26 2020
This content is from: Global

Asia Tax Awards 2020: The winners

The winners of the ITR Asia Tax Awards have been announced in a webinar presentation.
By Prin Shasiharan
August 26 2020
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Evaluating the new instrument of securing tax safety in Poland

Agnieszka Wnuk of MDDP considers the utility and effectiveness of the ‘securing opinion’, a specific protective tax ruling available in Poland.
By Agnieszka Wnuk

& MDDP
August 25 2020
This content is from: Netherlands

Unilever’s Dutch exit tax liabilities may rest on CJEU decision

Advisors expect the controversial Dutch proposal to levy exit taxes on corporate relocations to be challenged at the Court of Justice of the European Union (CJEU), saving Unilever a €11 billion exit tax bill.
By Danish Mehboob
August 24 2020
This content is from: Global

Digital audits risk alienating MNEs from revenue authorities

Multinational enterprises (MNEs) are concerned that an increase in digitisation and anonymity is jeopardising their relationships with tax authorities as COVID-19 forces an increase in online interactions.
By Alice Jones
August 24 2020
This content is from: United Kingdom

What UK taxes could be raised to cover COVID-driven spending?

Brian Peccarelli, chief operating officer at Thomson Reuters, examines what UK taxes are likely to rise in the near term to plug coronavirus spending, and what the challenges will be for CFOs.
By Brian Peccarelli
August 24 2020
This content is from: Global

This week in tax: Mastercard’s India case, tax treaties, and trade

In the week that Joe Biden became the US Democratic Party’s presidential nominee, the tax world has been dealing with several key court cases, more transfer pricing (TP) measures, and trade developments.
By Anjana Haines
August 21 2020
This content is from: Global

Cross-border tax information exchange is a game-changer

Sanjeev Sharma, principal director of income tax at the India Income Tax Department, discusses the exchange of tax information developments of the past decade and what needs to happen next.
By Sanjeev Sharma
August 18 2020
This content is from: Global

UN digital tax proposal diverges from OECD two-pillar solution

The United Nations (UN) tax committee’s default gross-based tax proposal to address the tax challenges of the digitalised economy differs from the OECD’s pillar one plan on several key features.
By Danish Mehboob
August 17 2020
This content is from: Podcast

Tax Talks: Marc Mokrab, Technicolor

ITR's Danish Mehboob asks Marc Mokrab, global tax director at Technicolor, about three key trends he sees influencing the future of the tax function: corporate responsibility, automation, and business partnering.
By Danish Mehboob
August 17 2020
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Malta: Applications now open for consolidating income tax

Ramona Azzopardi, Fiorella San Martin and Arthur Henrique Pasquini of WH Partners evaluate the key benefits of the Consolidated Group (Income Tax) Rules in Malta.
By Arthur Henrique Pasquini Filho

& Fiorella San Martin

& Ramona Azzopardi

& WH Partners
August 17 2020
This content is from: Global

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
August 14 2020
This content is from: Global

How to avoid being exposed to tax disputes

Many years ago, I was responsible for a tax group that reported to a regional group services organisation and not to the global head of tax. A new manager, with no experience of tax, had just taken over responsibility...
By Giles Parsons
August 14 2020
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Decoding the Indian dividend tax regime

Mehul Bheda and Saurabh Shah of Dhruva Advisors discuss how changes to the taxation of dividends has created a favourable economic environment for foreign investors.
By Dhruva Advisors

& Mehul Bheda

& Saurabh Shah
August 14 2020
This content is from: Global

How COVID-19 changed the tax world

The COVID-19 pandemic has hit businesses and their employees hard, as well as the wider domestic and global economies.
By Josh White
August 14 2020
This content is from: Global

Market insight

There have been some significant new hires across a range of tax firms around the world.
By Jon Moore
August 14 2020
This content is from: Global

How to prevent a tax dispute or mitigate its damage

Opportunities to come to a resolution with the tax authorities are generally better the earlier they present themselves in the life-cycle of a tax dispute, says Sandy Markwick, head of the Tax Director Network (TDN) a...
By Sandy Markwick
August 14 2020
This content is from: Global

Tax controversy: Heavyweight audits on the rise

Tax certainty has taken a big hit from the COVID-19 pandemic after already suffering from cross-border issues in a post-BEPS environment. Danish Mehboob explains how tax dispute management tools will be less effective...
By Danish Mehboob
August 14 2020
This content is from: Global

Americas Tax Awards 2020: Shortlist announced

The shortlist for the ITR Americas Tax Awards 2020 has been announced.
By Prin Shasiharan
August 13 2020
This content is from: Global

Americas Tax Awards 2020: Reactions

Leading firms react to their nominations at the ITR Americas Tax Awards 2020.
By Prin Shasiharan
August 13 2020
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Tax treaty benefits for partnerships investing in China

Lewis Lu of KPMG China explains that despite the recent easing of foreign investment restrictions, significant barriers to access DTA relief still remain in China
By KPMG China

& Lewis Lu
August 12 2020
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Italian courts consider costs deductibility for corporate income tax

Gian Luca Nieddu and Barbara Scampuddu of Hager & Partners explore the judicial decision which noted that costs deductibility is confirmed, even if the effective supplier and invoice issuer are different.
By Barbara Scampuddu

& Gian Luca Nieddu

& Hager & Partners
August 11 2020
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Romania: OECD guidelines on tax residence evoke uncertainty

Claudia Sofianu and Geanina Ciorâţă of EY Romania consider the tax implications arising from restrictions on the free movement of the workforce as a result of the coronavirus pandemic.
By Claudia Sofianu

& EY Romania

& Geanina Ciorata
August 11 2020
This content is from: United States

California Office of Tax Appeals goes digital

The COVID-19 pandemic is requiring courts and US state agencies to change the way they work. More virtual hearings and digital processes are a growing trend.
By Anjana Haines
August 11 2020
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Hong Kong SAR issues updated guidance on DIPN 42

Lewis Lu and John Timpany of KPMG analyse the taxation of financial instruments and foreign exchange differences and its impact on taxpayers.
By John Timpany

& KPMG Hong Kong

& Lewis Lu
August 11 2020
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US: Tax Court to decide on foreign taxpayer’s right to deductions in Adams Challenge

Mark Martin and Thomas Bettge of KPMG in the US report on the next steps in the Adams Challenge case following the tax court’s decision on the taxability of continental shelf charter income.
By KPMG US

& Mark Martin

& Thomas Bettge
August 10 2020
This content is from: India

MNEs predict Indian faceless e-assessments will increase litigation

Tax directors are worried that faceless e-assessments are creating a communication gap between taxpayers and the Indian Revenue Service (IRS) that could see the number of court cases rise.
By Alice Jones
August 10 2020
This content is from: United Kingdom

Enhanced UK scrutiny on corporate tax evasion procedures

The UK is set to increase tax evasion enforcement because of the widening COVID-19 financial deficit. Both domestic and foreign companies should closely review their exposure under the corporate criminal offences prov...
By Contributor
August 10 2020
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Tax policies to feature prominently in New Zealand’s general election

Brendan Brown and Mitchell Fraser of Russell McVeagh explain how tax policies are set to play a pivotal role as the people of New Zealand head to the polls.
By Brendan Brown

& Mitchell Fraser

& Russell McVeagh
August 09 2020
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Brazil: STJ confirms tax treaty benefits apply on cross-border services income

Alvaro Pereira and Mark Conomy of PwC Brazil take a look at a key STJ decision will assist companies carrying out cross-border transactions.
By Alvaro Pereira

& Mark Conomy

& PwC Brazil
August 07 2020
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Malta adopts tax measures to stimulate economy

Donald Vella and Kirsten Debono Huskinson of Camilleri Preziosi Advocates discuss how the Maltese government have moved to revitalise the economy and assist taxpayers affected by the COVID-19 outbreak.
By Camilleri Preziosi

& Donald Vella

& Kirsten Debono Huskinson
August 07 2020
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Indonesia imposes VAT on imported digital supplies

Jeklira Tampubolon and Aditya Nugroho of GNV Consulting lay out the rules regarding the upcoming imposition of VAT on the use of intangible goods and taxable services imported into Indonesia via electronic systems.
By Aditya Nugroho

& GNV Consulting

& Jeklira Tampubolon
August 06 2020
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Chile takes steps to embrace tax opportunities from foreign investors

Macarena Bevilacqua and Mauricio Ramírez of PwC Chile explain how the country has incorporated provisions to remain attractive for entrepreneurs.
By Macarena Bevilacqua

& Mauricio Ramírez

& PwC Chile
August 06 2020
This content is from: Market Insight

Strong recruitment plan crucial to appoint the best judges, says Chief Counsel

Kristen Kane, chief counsel of California's Office of Tax Appeals (OTA), talks to ITR about how the agency manages the struggle to recruit the best judges.
By Anjana Haines
August 04 2020
This content is from: Direct Tax

Dutch exit tax discourages MNEs from leaving

The Netherlands is expanding its dividend withholding tax (WHT) regime by adding an exit tax on companies such as Unilever that reorganise and move profit reserves to countries that do not impose Dutch dividend WHT.
By Danish Mehboob
August 03 2020
This content is from: Saudi Arabia

Tax Talks: Hany Elnaggar, Nissan

ITR reporter Danish Mehboob asks Hany Elnaggar, head of tax for Nissan in the Middle East, about transfer pricing in the Gulf Cooperation Council (GCC) countries, including audits in Saudi Arabia, and challenges to h...
By Danish Mehboob
August 03 2020

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