This content is from: Sponsored Top 20 questions and answers on new GloBE Model Rules Commentary KPMG experts provide answers to a selection of questions arising from the Inclusive Framework’s 228-page commentary released on March 14 2022. By Chris Morgan & Conrad Turley & David Linke & Grant Wardell-Johnson & KPMG Global & Manal Corwin & Vinod Kalloe March 31 2022
This content is from: Global Amazon’s institutional investors want GRI tax transparency Institutional investors with $3.6 trillion in combined assets are looking for a legal route to vote for Amazon to disclose tax receipts in countries where it operates, at the next shareholders meeting in April. By Danish Mehboob March 31 2022
This content is from: Sponsored The EU updates tax ‘grey-list’ as Hong Kong SAR plans for tax law changes Lewis Lu and John Timpany of KPMG China discuss the EU’s latest update in its tax ‘grey-list’ and the potential considerations for businesses from a Hong Kong SAR tax perspective. By John Timpany & KPMG China & Lewis Lu March 31 2022
This content is from: Sponsored Beneficial ownership in South Korea: Tax audit, appeal and planning opportunities Kyu Dong Kim, Yong Whan Choi, Min Young Sung and Ja-Young Lee of Yulchon consider the tax audit, appeal and planning opportunities concerning beneficial ownership involving South Korean inbound investments. By Ja-Young Lee & Kyu Dong Kim & Min Young Sung & Yong Whan Choi & Yulchon March 30 2022
This content is from: Sponsored 10 points on how leaders can prepare for upcoming GloBE rules Experts from KPMG consider what multinationals can do in preparation for the OECD’s upcoming commentary release on GloBE rules. By Grant Wardell-Johnson & KPMG Global March 28 2022
This content is from: Sponsored New Zealand: Consults on taxation of the gig and sharing economy Fred Ward and Young-chan Jung of Russell McVeagh examine proposals to reform information reporting and GST in a recent discussion document on the gig and sharing economy. By Fred Ward & Russell McVeagh & Young-chan Jung March 28 2022
This content is from: Sponsored Indonesia: Changes to tariffs, reporting and tax rates Charles Oetomo and Welly Armantha Napitupulu of GNV Consulting round up recent tax-related announcements from the Indonesian government including those affecting electric-based vehicles, construction services, luxury ... By Charles Oetomo & GNV Consulting & Welly Armantha Napitupulu March 28 2022
This content is from: Sponsored Carta Porte will be a logistical challenge in Mexico Ángel Escalante Carpio and Juan Manuel Morán of Escalante & Asociados discuss a new tool to tackle smuggling and informal trade in Mexico, which imposes a significant burden on taxpayers. By Ángel Escalante Carpio & Escalante & Asociados & Juan Manuel Morán March 25 2022
This content is from: Sponsored Webinar: Tax engines - An essential tech for EU and global organisations ITR and Thomson Reuters hosted a webinar on April 28 to share insights into how tax engines can help businesses meet the needs in an increasingly complex tax environment. By Juergen Wendel & Laurence Pollinsky & Michiel Ruys & Thomson Reuters March 25 2022
This content is from: Global This week in tax: Countries respond to Ukraine war with tax proposals The tax implications of the Russia-Ukraine war continue to dominate headlines this week with governments proposing measures to counter soaring energy and fuel prices, change beneficial ownership rules and target crypt... By Anjana Haines March 25 2022
This content is from: Sponsored Singapore: Tax highlights of the Budget 2022 Sivakumar Saravan and Liew Kin Meng of Crowe Singapore provide the key highlights of the proposed tax changes announced in the Singapore Budget 2022. By Crowe Singapore & Liew Kin Meng & Sivakumar Saravan March 25 2022
This content is from: Sponsored Australia applies freezing orders against foreign-owned company Kelvin Yuen of DLA Piper discusses a case where Australia’s Federal Court applied freezing orders to avoid sales proceeds being transferred outside of Australia. By DLA Piper Australia & Kelvin Yuen March 24 2022
This content is from: Sponsored Poland: CIT exemption for companies attracts foreign investors Łukasz Kosonowski of MDDP discusses the new Polish income tax regime and explains how foreign investors may use it to increase competitiveness of their businesses. By Łukasz Kosonowski & MDDP March 24 2022
This content is from: United Kingdom UK government prepares for 2024 election with budget’s tax proposals UK Chancellor Rishi Sunak focused on tax-cutting measures and efficiencies in his Spring Statement ahead of the 2024 general election. Businesses, however, will have to wait until the Autumn Budget to see significant ... By Anjana Haines March 23 2022
This content is from: Sponsored Clarificatory amendments to Indian tax laws: Retrospective levies in disguise? S Vasudevan and Harshit Khurana of Lakshmikumaran & Sridharan discuss the implications of certain ‘clarificatory’ amendments proposed in Indian tax laws on previous disputes. By Harshit Khurana & Lakshmikumaran & Sridharan & S Vasudevan March 23 2022
This content is from: Sponsored Norway: Proposal on widening Norway’s taxation right on the continental shelf Margrethe Tranøy Hovde and Henna Maria Råd Valderhaug of Deloitte Norway explain proposed new rules for a wider taxation right for Norway on the continental shelf. By Deloitte Norway & Henna Maria Råd Valderhaug & Margrethe Tranøy Hovde March 23 2022
This content is from: Sponsored Greek tax considerations commonly encountered in private share deals Maria Zoupa and Daphne Cozonis of Zepos & Yannopoulos discuss some of the tax considerations usually relevant for both sellers and buyers when planning and negotiating the transactional part of such acquisitions of no... By Daphne Cozonis & Maria Zoupa & Zepos & Yannopoulos March 22 2022
This content is from: Sponsored Dutch fiscal unity regime: Advantages and disadvantages after acquisition Jurgen van Hattum and Victor Kloosterman of Grant Thornton discuss the pros and cons of the Dutch fiscal unity regime. By Grant Thornton & Jurgen van Hattum & Victor Kloosterman March 22 2022
This content is from: Sponsored Aggravated taxation of blacklisted jurisdictions: Winds of change for Portugal? Raquel Maurício of Morais Leitão considers aggravated taxation imposed in connection to blacklisted jurisdictions and ECJ case law. By Morais Leitão, Galvão Teles, Soares da Silva & Associados & Raquel Mauricio March 22 2022
This content is from: Sponsored Mexican issuers to file new report on the sale of shares between foreign residents Juan José Paullada and Eric Palacios of Ritch Mueller explain why the new report’s due compliance and enforceability still carries complexities By Eric Palacios & Juan José Paullada & Ritch Mueller March 21 2022
This content is from: European Union This week in tax: EU finance ministers disagree on pillar two EU finance ministers disagreed over the draft directive to implement the OECD's pillar two plan. The lack of unanimity may hold back the plan for a 15% minimum corporate tax rate. By Danish Mehboob & Josh White & Leanna Reeves March 18 2022
This content is from: Global ITR Global Tax 50 2021-22 Global Tax 50 highlights the most influential individuals, organisations and geopolitical events in the tax world. Acting Managing Editor Josh White introduces the 2021-22 edition of the landmark feature. By Alice Jones & Anugraha Sundaravelu & Danish Mehboob & Josh White & Leanna Reeves March 17 2022
This content is from: Global Tensions escalate over sanctions relating to Russia-Ukraine war As the US and its allies limit trade with Russia in response to its invasion of Ukraine, China refuses to participate. The Russia-Ukraine conflict is generating further tension between China and the US over trade. By Alice Jones March 16 2022
This content is from: Sponsored Tax developments impacting climate change in Ireland David Neary and Alan Kilmartin of Deloitte Ireland provide an overview of taxation changes which may impact on the deployment and cost efficiency of climate change initiatives in Ireland. By Alan Kilmartin & David Neary & Deloitte Ireland March 15 2022
This content is from: Sponsored Recent changes to section 174 of the US Internal Revenue Code Mark Martin and Thomas Bettge of KPMG in the US describe changes to section 174 of the US Internal Revenue Code and what this may mean for entities that provide contract research and development services to related pa... By KPMG US & Mark Martin & Thomas Bettge March 14 2022
This content is from: Direct Tax Russian aggression offers several tax lessons for governments Russia’s invasion in Ukraine has expedited some international tax developments including regulations on digital assets and beneficial ownership, as well as revisions on environmental tax incentives. By Danish Mehboob March 14 2022
This content is from: Russia Russia boosts tax incentives as businesses exit the country Russia is enhancing its already favourable local tax regimes to support several growth sectors. At the same time, the Big Four accountancy firms have severed ties with their Russian offices. By Danish Mehboob March 11 2022
This content is from: United States This week in tax: Russian tax treaties in doubt? As the Russia-Ukraine war continues, the US considers tougher economic sanctions against Russia and some politicians are wondering if this is the time to reconsider the US-Russia tax treaty. By Danish Mehboob & Josh White & Leanna Reeves March 11 2022
This content is from: Direct Tax 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 March 10 2022
This content is from: Transfer Pricing ITR Global Tax 50 2021-22: Pillar two The OECD’s digital tax agenda is set to still be the hottest topic in tax policymaking in 2022, as many countries prepare the groundwork for a 15% global minimum corporate tax rate by 2023. By Danish Mehboob March 10 2022
This content is from: Transfer Pricing ITR Global Tax 50 2021-22: Pillar one Pillar one represents the most ambitious tax reform proposal in a century. The OECD may have secured global support for the two-pillar solution, but there is still a lot of work to do. By Josh White March 10 2022
This content is from: Direct Tax ITR Global Tax 50 2021-22: Boris Johnson UK Prime Minister Boris Johnson may no longer be the triumphant Conservative leader he was in 2019, but he has redefined UK tax policy in response to COVID-19. By Josh White March 10 2022
This content is from: Direct Tax ITR Global Tax 50 2021-22: Sri Mulyani Indrawati Indonesian Minister of Finance Sri Mulyani Indrawati is chairing the G20 meetings on tax in 2022 and will be advocating for carbon taxes and other environmental tax measures based on her domestic reforms. By Danish Mehboob March 10 2022
This content is from: Direct Tax ITR Global Tax 50 2021-22: Holdout nations Four global south nations refused to sign up to the OECD-brokered agreement on the two-pillar solution to digital tax. Kenya, Nigeria, Sri Lanka and Pakistan all opposed the agreement. By Josh White March 10 2022
This content is from: Direct Tax ITR Global Tax 50 2021-22: Paolo Gentiloni European Commissioner for the Economy Paolo Gentiloni is set to play a crucial role in securing digital tax reform in the EU as the union moves to enact the OECD’s two-pillar plan. By Josh White March 10 2022
This content is from: Direct Tax ITR Global Tax 50 2021-22: Diversity & inclusion initiatives Diversity and inclusion (D&I) initiatives have swept tax departments around the world in the last year, but there is still a lot of work to be done to ensure tax teams are representative. By Anugraha Sundaravelu March 10 2022
This content is from: Direct Tax ITR Global Tax 50 2021-22: Paschal Donohoe Irish Finance Minister Paschal Donohoe is about to embark on tax reform as Ireland moves away from its longstanding corporate tax policy in favour of a higher rate. By Josh White March 10 2022
This content is from: Direct Tax ITR Global Tax 50 2021-22: Crypto-assets Crypto-assets from Bitcoin to non-fungible tokens (NFTs) have become the focus of a global tax crackdown over widespread concerns of tax evasion and avoidance. By Josh White March 10 2022
This content is from: Direct Tax ITR Global Tax 50 2021-22: COVID-19 The virus that changed the world continues to create problems for taxpayers. By Josh White March 10 2022
This content is from: Direct Tax ITR Global Tax 50 2021-22: Raquel Buenrostro Sánchez Mexico’s ‘Iron Lady’ tax chief Raquel Buenrostro continues to crack down hard on tax evasion, while looking to close tax loopholes for multinational companies. By Josh White March 10 2022
This content is from: Direct Tax ITR Global Tax 50 2021-22: Joe Biden US President Joe Biden came to power promising to reform the US tax code as part of an ambitious economic platform. Yet the roadmap for tax reform is still uncertain. By Josh White March 10 2022
This content is from: Direct Tax ITR Global Tax 50 2021-22: Black Tax Matters Brazilian group Black Tax Matters (BTM) is fighting for greater diversity in the tax profession. By Anugraha Sundaravelu March 10 2022
This content is from: Direct Tax ITR Global Tax 50 2021-22: Anton Siluanov Russia’s Minister of Finance Anton Siluanov is tasked with overseeing the country’s fiscal strategy amid mounting international sanctions. By Josh White March 10 2022
This content is from: Direct Tax ITR Global Tax 50 2021-22: John Peterson John Peterson, head of the OECD’s aggressive tax planning unit, is responsible for pillar two’s global minimum tax framework. About 137 countries are drafting minimum taxes based on his design. By Danish Mehboob March 10 2022
This content is from: Direct Tax ITR Global Tax 50 2021-22: Will Morris Will Morris has taken on the role of vice chairperson of the BIAC tax and fiscal affairs committee. He will continue to help shape the tax agenda in 2022. By Danish Mehboob March 10 2022
This content is from: Direct Tax ITR Global Tax 50 2021-22: The rise of Britacom The Belt and Road Initiative Tax Administration Cooperation Mechanism (Britacom) is set to become ever more important as BRI jurisdictions open special economic zones to bolster investment. By Josh White March 10 2022
This content is from: Direct Tax ITR Global Tax 50 2021-22: Fumio Kishida Japanese Prime Minister Fumio Kishida wants to redefine Japanese capitalism and tax policy will be a key part of his strategy. By Josh White March 10 2022
This content is from: Direct Tax ITR Global Tax 50 2021-22: Michael Lennard Michael Lennard, chief of international tax cooperation at the UN’s Financing for Development Office, plans to get back to a wide range of tax issues neglected during the digital tax debate. By Josh White March 10 2022
This content is from: Direct Tax ITR Global Tax 50 2021-22: The Gulf Cooperation Council Tax fragmentation continues in the Gulf Cooperation Council (GCC) countries with varying VAT systems and corporate tax rates. Both Saudi Arabia and the United Arab Emirates have taken unilateral action, but others may... By Danish Mehboob March 10 2022
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 March 10 2022
This content is from: Global ITR celebrates International Women’s Day 2022 To mark International Women’s Day 2022, ITR showcases some of the best talent across the global tax sector through interviews, articles and panel discussions. By ITR Editorial March 08 2022
This content is from: Sponsored A closer look at taxation of private equity and funds in India In light of the increasing foreign investment in Indian companies, Uday Ved and Amitabh Khemka of KNAV discuss the tax implications of different types of investment. By Amitabh Khemka & KNAV India & Uday Ved March 08 2022
This content is from: Sponsored Greece gains investment activity from foreign private equity funds Michael Stefanakis of Deloitte Greece explains how investors can avoid certain pitfalls when considering tax structures for foreign private equity funds. By Deloitte Greece & Michael Stefanakis March 08 2022
This content is from: Sponsored Mexican tax reform and its impact on the M&A market Tax reforms introduced in 2022 aim to tackle tax loopholes and strengthen mechanisms enabling tax authorities to perform audits and collect taxes, as Federico Scheffler and Sebastián Ayza of Galicia Abogados explain. By Federico Scheffler & Galicia Abogados & Sebastián Ayza March 08 2022
This content is from: Sponsored Italy’s PEX regime raises doubts among taxpayers Luca Galliani of LED Taxand takes a closer look at recent amendments to Italy’s PEX regime in case of foreign subsidiaries, and considers why taxpayers may need further clarity. By LED Taxand & Luca Galliani March 08 2022
This content is from: Sponsored Continuing to boom - ITR's M&A Special Focus launched ITR has partnered with leading tax advisors from across the globe to provide insights into M&A activity in 2022 and beyond. By Lorraine Yardley March 08 2022
This content is from: Sponsored M&A tax considerations for PE transactions in Asia-Pacific The growth of PE activity in Asia-Pacific gives rise to unique tax challenges. Amrish Shah, Daniel Ho, Brett Todd and Dwight Hooper of Deloitte provide tips for both acquirers and those looking to do deals in the region. By Amrish Shah & Brett Todd & Daniel Ho & Deloitte & Dwight Hooper March 08 2022
This content is from: Sponsored Strategising M&A tax in Mexico Miguel Llovera, Gabriela Sansores Fernandez and Eduardo Vivanco of Deloitte Mexico describe how strategising M&A tax while conducting a deal supports the value creation journey. By Deloitte Mexico & Eduardo Vivanco & Gabriela Sansores Fernandez & Miguel Llovera March 08 2022
This content is from: Sponsored Recapitalisations raise tax issues in Switzerland Many businesses have required recapitalisation due to the COVID-19 pandemic. Bastian Thurneysen and Rolf Wüthrich of burckhardt explain why it is vital to consider how capital is provided to avoid any tax problems. By Bastian Thurneysen & Burckhardt & Rolf Wüthrich March 08 2022
This content is from: Global Governments prepare top-up taxes to make pillar two work Qualified domestic minimum top-up taxes (QDMTTs) allow jurisdictions to introduce a minimum corporate rate and maintain a competitive tax regime. By Danish Mehboob March 07 2022
This content is from: Sponsored New European rules supporting businesses to achieve Green Deal objectives Gilles Van Hulle and Pierre Demoulin of PwC Belgium discuss the European Green Deal and explain why member states must also comply with existing state aid rules. By Gilles Van Hulle & Pierre Demoulin & PwC Belgium March 07 2022
This content is from: Sponsored Impact of Mexico’s ‘controlling beneficiary’ rules Santiago Llano and Eduardo García of Ritch Mueller analyse the impact and relevance of the Mexico’s ‘controlling beneficiary’ rules, including several issues arising due to their poor implementation. By Eduardo García & Ritch Mueller & Santiago Llano March 07 2022
This content is from: Europe This week in tax: Ukraine crisis could fuel crypto tax crackdown Crypto exchanges resisting calls for a trading ban on Russia amid the Ukraine war could face a wider crackdown from tax authorities around the world. By Danish Mehboob & Josh White & Leanna Reeves March 04 2022
This content is from: Sponsored Indonesia updates rules on tax facilities, withholding tax and tax incentives Ahdianto and Julius Wahyu of GNV Consulting discuss the latest developments on tax facilities and COVID-19, unification withholding tax returns and tax incentives affected by COVID-19. By Ahdianto Ah & GNV Consulting & Julius Wahyu Daryono March 04 2022
This content is from: Sponsored The legal uncertainty surrounding management packages in France and prospective solutions Further to recent case law, Nicolas Duboille and Hugo Levit of Sumerson, discuss the potential use of alternative legally bound tools in the context of management packages that may be efficient from a tax and social c... By Hugo Levit & Nicolas Duboille & Sumerson March 03 2022
This content is from: Sponsored Webinar: Common challenges and practical tips in ERP localisation projects ITR and TMF Group hosted a webinar on March 31 to discuss the common pitfalls in ERP localisation projects and practical matters that should be prioritised in finance teams’ agenda. By Csaba Farkas & TMF Group March 03 2022
This content is from: Europe ITR Global Tax 50: Olaf Scholz German Chancellor Olaf Scholz is committed to global tax reform and tackling climate change, but he is already being put to the test by an international crisis. By Alice Jones March 02 2022
This content is from: Global ITR Global Tax 50 2021-22: Beneficial ownership Beneficial ownership has been highlighted by court cases and scandals. It is a part of key provisions for multinational enterprises (MNEs) to seek treaty benefits, and some companies have even restructured because of it. By Danish Mehboob March 02 2022
This content is from: Sponsored What the 'unshell' directive proposal means for Portugal Miguel Teles of Morais Leitão discusses the likely impact of the proposal for a directive regarding shell entities and the issues it raises regarding abuse. By Miguel Teles & Morais Leitão, Galvão Teles, Soares da Silva & Associados March 01 2022
This content is from: Sponsored China: Individual income tax policy changes implemented There were a number of important reforms affecting individual income tax in China at the turn of 2022. Lewis Lu of KPMG explains what they mean for taxpayers. By KPMG China & Lewis Lu March 01 2022