July/August 2018
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International Correspondents
Features
New Analysis
Tax Relief
Special Features
Editorial
Sponsored
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Sponsored by KPMG Hong KongIn recent years, the Hong Kong government has introduced various incentives to bolster Hong Kong as an international finance centre by extending the offshore funds exemption and special purpose vehicle (SPV) exemption.
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Sponsored by Deloitte SwitzerlandOn June 7 2018, the Swiss Senate passed the revised so-called Swiss Corporate Tax Reform 17 Bill following the recommendations of its Ways and Means Committee.
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Sponsored by Deloitte LuxembourgOn April 16 2018, the draft Bill introducing a VAT group regime in Luxembourg was made public.
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Sponsored by KPMG RussiaDmitry Garaev and Anastasia Avdonina analyse the Russian Federal Tax Service's interpretation of the concept of beneficial ownership.
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Sponsored by Russell McVeaghImportant BEPS-related reforms have moved a step closer to becoming law in New Zealand.
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Sponsored by KPMG ChinaIn recent years the Chinese government has progressively replaced administrative pre-approvals for various tax treatments and regulatory licences with tax authority record filing requirements. This has been coupled with more targeted and effective procedures for follow-up audit and review.
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Sponsored by DLA Piper AustraliaThere have been a number of important Australian tax developments recently that affect offshore businesses/investors and their inbound investments into Australia.
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Sponsored by MDDPOn July 1 2018, the Polish VAT Act of 11/03 2004 is to be amended by a new regulation introducing a voluntary split payment as a method of payment of purchase invoices – from the perspective of taxpayers – and as a new tool to combat VAT fraud – from the perspective of tax authorities. However, from the perspective of VAT taxpayers the new mechanism may bring more radical changes than expected in some areas.
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Sponsored by NeraThe OECD BEPS initiative has introduced numerous likely challenges to transfer pricing structures defended through application of the transactional net margin method (TNMM). This article focuses on the economic analysis enhancements needed to make TNMM-type transfer pricing solutions sustainable in the future.
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Sponsored by Webber WentzelThe use of real estate investment trusts (REITs) is becoming increasingly popular in South Africa. However, care needs to be taken where a South African REIT holds various foreign property owning subsidiaries either directly or through a non-South African intermediary holding company (IHC).
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Sponsored by Dhruva AdvisorsRecently, the Income Tax Appellate Tribunal gave an important judgement regarding the creation of and attribution of profits to an agency permanent establishment (Agency PE) – Daikin Industries v ACIT ('ITA No 1623 of 2015 [New Delhi Income Tax Appellate Tribunal, May 28 2018]').
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Sponsored by Hager & PartnersFollowing a public consultation on draft regulations designed to provide operational guidance on transfer pricing in line with the international evolution that has occurred at OECD level (the BEPS project), the Italian Ministry of Economy and Finance issued the Decree of May 14 2018 on the application of the arm's-length principle based on international best practices (published in the Official Gazette number 118 of May 23 2018).