October 2018

Main

Luxembourg’s new VAT grouping regime has plenty of downsides

Market insight: EY’s takeover of Riverview Law

Americas Tax Awards 2018

US tax reform 2.0 advances at frantic pace

Tax disputes put $75 billion of Fortune 500 profits in the firing line

Wayfair and the Dunkin’ Donuts philosophy

Why Grant Thornton and BDO want audit reform

Brazil: Amendments to protocol to Brazil and Argentina tax treaty enacted

It’s always an eventful month

Chief strategic officer: A new world

Vodafone’s Glenn Price talks tax and risk

Tax planning amid political instabilities and tax grabs

Special features - October 2018

Albania: Albania changes income tax law, introduces incentives for agro-tourism

Australia: MLI, hybrid mismatch, MITs and staple structures, cross-border financing and reduced company tax rate

Bulgaria: Bulgaria allows electronic storage of employment documents

Canada: ‘Partnerships’ in Canada

Chile aiming to join era of indirect tax on digital services

China: Tax support for innovation and new regulatory framework for e-commerce

Croatia: Tax incentives for research and development in Croatia

Egypt: Central Bank of Egypt defends bank accounts secrecy

European Union: Outgoing Juncker commission’s plans for tax until November 2019

Georgia: Georgia concludes double taxation treaty with Saudi Arabia

Germany: Using statistical analysis to improve TNMM

Hong Kong: Recent accounting changes in Hong Kong

Indian tax treaty benefits available without providing a tax residency certificate

Indonesia: Commencement of AEOI and priority target for tax audit

Italy: Intercompany charges, cost inherence and deductibility

Luxembourg: VAT committee publishes guidelines on VAT treatment of cash pooling

Montenegro: Citizenship by investment in Montenegro

Netherlands: Dutch participation exemption and the write-down of receivables

New Zealand: New Zealand issues draft guidance on BEPS-related reforms

Poland: Income tax on buildings: Amendments

Portugal: Liquidation proceeds sourced in Spain and exemption method for non-habitual tax residents

Tax audits – a disruptive routine for every taxpayer

Serbia: Serbia amends VAT Law, extending eligibility for VAT refund to foreign companies

South African dividend stripping rules: Impact on liquidations and cross-border share buybacks

Switzerland: EU DAC6 mandatory disclosure rules – why should Swiss intermediaries care?

Turkey: Recent tax developments

US Inbound: Altera decision reversal withdrawn

US Outbound: New updates to CAP focus on transfer pricing issue resolution

The GP Surgery: Certainty, secrecy and DAC16

Tax Relief

Robert McGuinness joins Marks Paneth in New Jersey

Euromoney Asia Women in Business Law Awards 2018: winners announced

International updates - October 2018

No. 1: David Bradbury & Giorgia Maffini

No. 2: Pierre Moscovici

No. 3: Digital tax – the outliers

No. 4: Artificial intelligence and the robot tax

No. 5: The US judicial system

No. 6: Brexit

No. 7: Donald Trump

No. 8: Pascal Saint-Amans and Achim Pross

No. 10: Margaret Hodge and Andrew Mitchell

No. 9: Monica Bhatia

International Correspondents

Features

New Analysis

Tax Relief

Special Features

Editorial

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Netherlands: Dutch participation exemption and the write-down of receivables

One of the key benefits of the Dutch tax system is the participation exemption regime, whereby benefits derived by Dutch corporate taxpayers from a qualifying shareholding (i.e. dividends, capital gains, and foreign exchange results) are fully exempt from Dutch corporate income tax (25%). This beneficial treatment of the participation exemption regime also applies to earn-out payments whereby the deferred instalment payments depend upon the performance of the company being sold.

Jian-Cheng Ku, October 15 2018

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