Magazine
April 2014

Magazine Archive

The global harmonisation of exchange of information

Corporate tax reporting in an era of exchange of information is still uncertain, but, as Samantha Merle, Sumeet Hemkar and Katrina Dautrich-Reynolds, of Taxand explain, taxpayers can still take steps to prepare for the introduction of new regulations.

Implications for maquiladoras of the 2014 Mexican tax reform

Ricardo León-Santacruz and Fernando Lujan of Sánchez-DeVanny Eseverri explain how the Mexican 2014 tax reform limits tax incentives and imposes new administrative burdens on the maquiladora sector, which is made up of wholly owned companies that process or assemble imported materials and parts into finished products for sale to the country of origin or other parts of the world.
India: Profit attribution to permanent establishments

Sanjay Sanghvi and Ashish Mehta of Khaitan & Co. analyse recent tax rulings dealing with the attribution of profits to permanent establishments, looking at what multinationals can do to avoid becoming embroiled in similar disputes in the future.
Operational TP: When tax function meets finance function

Frank Schoeneborn, head of global operational transfer pricing in the finance and accounting division at Merck Group with headquarters in Germany, looks at the practical problems in the implementation of operational transfer prices, illustrating the new tax risks stemming from these problems and showing how holistic management can be the solution.
EU breakthrough on Savings Tax Directive
Bradbury to head OECD’s tax policy unit
Nelson joins Morgan Lewis in Boston
Aurélia de Viry launches King & Spalding’s French tax practice
Two tax barristers become QCs in UK
Baker & McKenzie recruits Clark from Heenan Blaikie
Rockwell Olivier hires Morris Maroon as head of tax
Bjørnholm leaves Hannes Snellman for Plesner
Fiszer joins GESSEL in Warsaw
Matthew Lerner joins Sidley Austin as tax controversy partner
Deals of the month

See who has done the tax work on this month’s biggest deals
Saint-Amans defends OECD’s CRS despite loopholes identified by TJN

By shining a spotlight on loopholes and failing legislation, the Tax Justice Network has been at the fore of global tax policy development in recent years. In its latest report, it praises the OECD's work on automatic information exchange, but identifies areas for improvement.
Obama and Camp plans show distance left to travel on US reform
Why Europe’s VAT system is taking time to achieve harmonisation
UK Budget: Welcome certainty for business as lobbying pays off
Semeta’s legacy: The Commissioner’s greatest achievements

Algirdas Semeta, European Commissioner for Taxation, Customs Union, Audit and Anti-Fraud, has proven himself to be an ambitious reformer over the past four years. As Semeta approaches the end of his term, Salman Shaheen speaks to him about his greatest achievements, and what he wants to do before he leaves Brussels.
Teamwork central to Telefônica’s tax compliance in Brazil

Vasco Gruber Franco is head of tax for the Telefônica group in Brazil. He previously worked on the advisory side at Arthur Andersen, and has held other in-house roles at DuPont and Philip Morris. Here, he talks to Matthew Gilleard about heading up a tax department in Brazil.
Europe’s plan for FTT fails to convince

Andrew Thomson of Sullivan & Cromwell believes the Robin Hood Tax Campaign's justification for an EU financial transaction tax, published in the February issue, is flawed.
Special features - April 2014

Read this month's special features on tax technology and India.
Albania: Albania changes its VAT legislation
Australia: Tax consolidation rules: Potential risk areas
Bosnia and Herzegovina: Tax Treaty between Bosnia & Herzegovina and Azerbaijan
Bulgaria: Constitutional Court revokes the unified account for tax payments
Canada: Extension of Canadian thin capitalisation rules announced
Chile: Tax treatment of capital reductions by the recipient entity
China: New China-France double tax agreement signed
Cyprus: Special defence contribution on dividends reverts to lower levels
EU: Update on the EU FTT
Hong Kong: Budget handed down
India: Delhi High Court rules on constitution of permanent establishment in outsourcing arrangements
Italy: Italy extends International Standard Ruling procedure
Luxembourg: VAT Update
FYR Macedonia: Reinstatement of withholding tax on dividends distributed to resident companies
Mexico: New mining and environmental royalties
Montenegro: Montenegro regulates taxation of hydrocarbon production activities
New Zealand: New Zealand enacts new laws relating to taxation of foreign superannuation interests
Serbia: Decree on conditions required for deferment of tax debt payment
South Africa: A modest Budget speech
Spain: Tax authorities disregard third-party’s remuneration by using secret comparables
Switzerland: Embracing the worldwide trend of increasing substance requirements
Switzerland : Itelcar: How Switzerland may benefit from Portuguese thin capitalisation rules
US Inbound: Obama Administration issues Green Book
Tax Relief

Because tax doesn’t have to be taxing.
Malaysia: The road to GST implementation

Implementing a goods and services tax (GST) regime can be a lengthy and turbulent process. With Malaysia looking to establish its own regime, Lachlan Wolfers, Asia-Pacific regional leader for indirect taxes at KPMG, explores the common pitfalls and looks at the lessons Malaysia can take from similar experiences in other jurisdictions.