This content is from: Sponsored Switzerland: Presenting a resilient and stable location in the heart of Europe René Zulauf and Manuel Angehrn of Deloitte Switzerland explain why international investors continue to flock to Switzerland amid the challenging economic environment. By Deloitte Switzerland & Manuel Angehrn & René Zulauf October 30 2020
This content is from: Sponsored Greece: Tax administration enhances digitalisation John Goulias of EY in Greece explains the key elements of the Independent Authority for Public Revenue’s platform for the transmission of fiscal data. By EY in Greece & John Goulias October 30 2020
This content is from: Sponsored France: The difficulty of applying anti-avoidance rules to trusts Nicolas Duboille of Sumerson looks at the decision in the Clive-Worms case, which confirms that anti-avoidance rules targeting undistributed profits realised in low-tax jurisdictions are not easily applicable to trusts. By Nicolas Duboille & Sumerson October 30 2020
This content is from: Global This week in tax: UN votes on Article 12B and banks respond to tax allegations In the week that the United Nations voted on whether to include a new provision, Article 12B, into the UN Model Tax Convention, EU research showed banks are still using legal loopholes to avoid tax. By Anjana Haines October 30 2020
This content is from: Sponsored Accounting & tax: The global and local complexities holding multinationals to account TMF Group reports on the global accounting and tax landscape, examining the growth of the digital economy and the impact of the COVID-19 crisis on markets worldwide. By TMF Group October 30 2020
This content is from: Sponsored A look at tax residence amid Spain’s COVID-19 state of alarm Jose Maria García-Valdecasas Alloza of García-Valdecasas & Viola assesses how Spain has approached the ‘duration of stay’ criterion for determining an individual´s tax residence during the coronavirus pandemic. By García-Valdecasas & Viola & Jose Maria García-Valdecasas October 30 2020
This content is from: Sponsored Singapore: Non-budget amendments from the Income Tax Amendment Bill 2020 Sivakumar Saravan and Liew Kin Meng of Crowe Singapore consider the key provisions from the amendments including the surcharge for tax avoidance arrangements, and car-related expenses. By Crowe Singapore & Liew Kin Meng & Sivakumar Saravan October 30 2020
This content is from: Sponsored Brazil: Tax authorities confirm treatment of foreign reimbursements related to partner-... Alvaro Pereira and Mark Conomy of PwC Brazil explain why the RFB’s publication of SC 2006/2020 has confirmed favourable outcomes for certain transactions although the consequences concerning the broader treatment of f... By Alvaro Pereira & Mark Conomy & PwC Brazil October 29 2020
This content is from: Global Register now: Research process for World Tax/TP and ITR Awards 2021 to be aligned Companies, firms and individuals can now register to be alerted for the beginning of the research for 2021’s global tax awards programme. By Jon Moore & Prin Shasiharan October 29 2020
This content is from: United Kingdom MNEs renew focus on CCO risks as HMRC steps up investigations Tax directors are turning their attention to the UK corporate criminal offence (CCO) rules to ensure they are compliant as the number of cases under review by HM Revenue and Customs (HMRC) increases once more. By Alice Jones October 29 2020
This content is from: Sponsored Romania: The tax consequences of working from anywhere Corina Mîndoiu and Cătălina Butan of EY Romania consider how national lockdowns have created fresh tax considerations for cross-border workers. By Cătălina Butan & Corina Mîndoiu & EY Romania October 29 2020
This content is from: Sponsored India: Vodafone’s tax woes continue to linger Ajay Rotti and Saurabh Shah of Dhruva Advisors discuss why the Indian government’s reluctance to accept the Vodafone ruling could have a detrimental effect for the international investor community. By Ajay Rotti & Dhruva Advisors & Saurabh Shah October 29 2020
This content is from: Sponsored US: Foreign-controlled CFCs - assessing the regulations for dealing with downward attri... William Skinner and Mike Knobler of Fenwick & West evaluate the final regulations, which had sought to address unintended consequences caused by the earlier repeal of Section 958(b)(4)’s limitation on downward attribu... By Fenwick & West & Mike Knobler & William Skinner October 28 2020
This content is from: Sponsored Australia: A look at the changes to the corporate residency test James Newnham of DLA Piper analyses the Australian government's interpretation of the ‘corporate residency’ test for non-Australian incorporated companies. By DLA Piper Australia & James Newnham October 28 2020
This content is from: Sponsored Poland: Evaluating the tax consolidation for groups regime Agnieszka Wnuk of MDDP explains the implications of recent developments concerning the consolidation of tax groups regime in Poland. By Agnieszka Wnuk & MDDP October 28 2020
This content is from: European Union EU proposals to advance its Green Deal to come in summer 2021 Gerassimos Thomas, director-general of European Commission’s taxation and customs union (DG TAXUD) explains the EU’s vision for a more environmentally friendly future and the two flagship priorities in his tax agenda ... By Gerassimos Thomas October 28 2020
This content is from: Sponsored Indonesia: Reduced tax rates offered to publicly listed companies Benjamin Simatupang and Fabian Abi Cakra of GNV Consulting highlight the key tax-related developments from September and October 2020 in Indonesia. By Benjamin Simatupang & Fabian Abi Cakra & GNV Consulting October 27 2020
This content is from: Sponsored Argentina: Inspecting the informative regime of tax planning strategies Ignacio Rodríguez and Juan Manuel Magadan of PwC Argentina assess the compliance campaign which will see increased monitoring of tax-planning strategies to prevent potential tax evasion. By Ignacio Rodríguez & Juan Manuel Magadan & PwC Argentina October 27 2020
This content is from: European Union Research suggests Europe’s largest banks continue to avoid tax Research by anti-corruption watchdog Transparency International EU (TI EU), carried out using country-by-country reporting (CbCR) data, suggests widespread use of profit shifting and tax havens among 39 of the largest... By Alice Jones October 27 2020
This content is from: Direct Tax OECD report moves crypto-assets closer to a uniform tax framework Tax administrations are planning to use the OECD’s recently released guidance to help standardise the tax treatment of crypto-assets in the digital economy that could include a financial transactions tax and more disc... By Danish Mehboob October 26 2020
This content is from: Sponsored Italy: The Supreme Court reports on the scope of the EU DRM Directive Gian Luca Nieddu and Barbara Scampuddu of Hager & Partners take a closer look at the Italian Supreme Court’s report on the recently introduced tax dispute resolution mechanisms. By Barbara Scampuddu & Gian Luca Nieddu & Hager & Partners October 23 2020
This content is from: Sponsored Hong Kong SAR: A look at the US executive order on shipping tax Lewis Lu and John Timpany of KPMG China analyse the impact of the US executive order on shipping taxes for Hong Kong SAR. By John Timpany & KPMG Hong Kong & Lewis Lu October 22 2020
This content is from: Transfer Pricing The OECD’s FTTP guidance may make tax authorities more aggressive The OECD’s guidance on financial transactions and transfer pricing (FTTP) may offer tax authorities extra tools in their pursuit of offshore financing structures in high stakes audits. By Josh White October 22 2020
This content is from: Sponsored New Zealand: Court of Appeal considers cross-border financing tax avoidance appeal Tim Stewart and Matt Woolley of Russell McVeagh discuss the key elements of Inland Revenue’s Court of Appeal win in a tax avoidance case against a leading Australasian drinks company. By Matt Woolley & Russell McVeagh & Tim Stewart October 21 2020
This content is from: Sponsored Economic stimulus initiatives head Australia’s 2020-21 budget Jock McCormack of DLA Piper summarises developments from Australia in October 2020, including the key takeaways from the federal budget and the latest guidance on the principal or main purpose test. By DLA Piper Australia & Jock McCormack October 20 2020
This content is from: Sponsored China: Tax measures to enhance Beijing as a services hub Lewis Lu of KPMG China looks at the transformational measures which will facilitate the flow of trade and investment in the Chinese capital. By KPMG China & Lewis Lu October 20 2020
This content is from: Sponsored A look at the new anti-hybrid mismatch arrangements rules in Portugal Ricardo Seabra Moura and Rita Pereira de Abreu of Vieira de Almeida analyse the challenges that lay ahead following the implementation of the rules. By Ricardo Seabra Moura & Rita Pereira Abreu & Vieira de Almeida October 20 2020
This content is from: Global COVID-19 introduces additional M&A tax risks and benefits M&A deals are vulnerable to tax risks that have emerged because of COVID-19, including those caused by employees working from home. Yet government aid may offer benefits to savvy buyers. By Alice Jones October 19 2020
This content is from: Global This week in tax: OECD and UN digital tax proposals released A political agreement on the OECD’s digital tax proposals will not happen before mid-2021, but stakeholders warn that the latest proposals are too complicated and create a significantly higher compliance burden. By Anjana Haines October 16 2020
This content is from: Direct Tax OECD’s blueprint on global minimum tax is a ‘compliance monster’ The OECD expects to reach an agreement on its two-pillar digital tax blueprints by mid-2021, but many stakeholders still say the approach is too complicated, while alternative tax proposals risk trade wars and multipl... By Danish Mehboob October 16 2020
This content is from: France France urges EU to introduce a DST France has said the European Union (EU) should introduce a digital services tax (DST) in case OECD discussions fail, while also confirming that the country will being levying its DST from mid-December. By Mattias Cruz Cano October 16 2020
This content is from: Global Webinar: Considerations when choosing a tax engine ITR and Vertex Inc hosted a live webinar at 3pm CET / 2pm BST / 9am EST on Thursday, November 12 to discuss the limitations of tax within SAP S/4 HANA and reveal more about the Vertex tax engine. See it on demand below. By Peter Boerhof & Prin Shasiharan & Roger Lindelauf & Vertex Inc October 16 2020
This content is from: Sponsored Norway: Amendments to R&D incentive scheme includes compliance changes Mette Lundal and Ragnhild Johannessen of Deloitte Norway explain the implications of the key amendments made to the Norwegian tax credit scheme for research and development (R&D) expenses. By Deloitte Norway & Mette Lundal & Ragnhild Johannessen October 14 2020
This content is from: United States Systematic approach vital to manage BEAT, FDII and GILTI changes Tax directors should consider related-party payments, the BEAT waiver election and local selling structures when modelling the outcomes of the US base erosion and anti-abuse tax (BEAT), foreign-derived intangible inco... By Alice Jones October 13 2020
This content is from: Global The OECD updates digital tax plan, consensus possible by mid-2021 The OECD released political and technical developments to its digital tax plans on October 12, but the COVID-19 pandemic impeded communication across stakeholders, delaying consensus on pillar one and two to 2021. By Danish Mehboob October 12 2020
This content is from: Global This week in tax: US elections worry corporate taxpayers In the week that the German Football Association was raided for suspected serious tax evasion, Australia announced corporate tax residency rules changes and concerns over the tax implications of the US elections incre... By Anjana Haines October 09 2020
This content is from: United States Corporate tax burdens will rise regardless of US election outcome Large businesses will likely see their effective tax rates rise regardless of the outcome of the US presidential election and changes to the GILTI rules appear inevitable. By Danish Mehboob October 08 2020
This content is from: Tax Disputes Taxpayers can be prevented from protecting their tax data, rules CJEU EU member states can prevent taxpayers subject to a tax investigation from launching a direct action against an information exchange request to prevent their financial data being shared, the Court of Justice of the Eu... By Alice Jones October 07 2020
This content is from: Global Carbon pricing is necessary for a green recovery In the wake of the COVID-19 crisis, green public spending is not enough for a green recovery. Decarbonisation requires carbon pricing, argue Kurt Van Dender, head of the tax and environment unit, and Jonas Teusch, tax... By Jonas Teusch & Kurt Van Dender October 07 2020
This content is from: United States US tax directors weigh up benefits and pitfalls of CARES Act MNEs should consider the drawbacks of incentives offered in the Coronavirus Aid, Relief, and Economic Security (CARES) Act, which include relaxing net operating loss (NOL) rules and changing the terms of section 163(j). By Alice Jones October 05 2020
This content is from: Direct Tax India’s Vodafone dispute continues to scare off foreign investment Vodafone’s victory in court against the Indian government will not stop controversial, retrospective tax collections on transfers in India, which continue to limit large business investments in the country. By Danish Mehboob October 05 2020
This content is from: Global This week in tax: Subway and Vodafone court battles end In the week that US President Donald Trump’s tax affairs caused more controversy, the Irish Supreme Court determined that Subway’s bread is too sweet to be bread and Vodafone won its Indian tax dispute. By Anjana Haines October 02 2020
