ITR Search | International Tax Review

Foreign employee secondments and the PE issue

Companies often second their employees to other firms in their group abroad but this can create a permanent establishment (PE) risk; something that can take up an unreasonable amount of time for a tax director if not handled properly. Sophie Ashley speaks to taxpayers and their advisers about how best to manage the situation to avoid creating a PE.

Sophie Ashley, September 30 2013

Vietnam: How to interpret the meaning of "an entity principally holding immovable property" under Vietnam's regulations

Thuan Pham, VDB Loi The Ministry of Finance of Vietnam has recently released for public comment a new draft circular that provides general guidance on the implementation of tax treaty clauses. In particular, it clarifies how to identify whether an entity is considered to be holding mostly immovable property when determining taxing rights on a non-resident's gain from a share transfer of such entity.

September 30 2013

Switzerland: Withholding tax refund on dividend transactions denied

Ferdinando Mercuri and Céline Dupasquier, Deloitte After two decisions in favour of tax payers with regards to withholding tax (WHT) refund in cases close to "dividend stripping scheme", the Federal Administrative Court (FAC) took an opposite decision on March 13 2013 and refused the refund of the WHT levied on dividends distributed by a Swiss company to a Swiss bank.

September 30 2013

BEPS: A new approach for taxing multinationals is needed - Part II

With international tax rules firmly in the spotlight, Mirna Screpante, invited tax researcher at the Max Planck Institute for Tax Law and Public Finance, takes another look at why a new approach for taxing companies is needed, and how this might look.

September 30 2013

Portugal: Portuguese corporate tax reform in the making: draft report proposals

Fernando Castro Silva and Tiago Cassiano Neves, Garrigues The Commission appointed by the Portuguese government to consider options for the Portuguese corporate income tax (CIT) reform has recently released its draft report, including a first draft law. The proposals are intended to modernise and further enhance the Portuguese corporate tax system and reflect changes in the global landscape. This update covers the key proposals affecting international investors.

September 30 2013

India: Administrative notifications prescribe additional reporting requirements in certain cross-border situations

Rajendra Nayak and Aastha Jain, EY The Central Board of Direct Taxes, the apex administrative authority of direct taxes in India, recently issued notifications prescribing additional reporting requirements under two circumstances, firstly, by a non-resident (NR) taxpayer to claim benefit under a tax treaty and secondly, by a person (remitter) responsible for making payments to a NR (recipient) which are chargeable to tax in India.

September 30 2013

FYR Macedonia: FYR Macedonia - Azerbaijan treaty enters into force

Elena Kostovska, Eurofast Global Speedy ratifications of the treaty between FYR Macedonia and Azerbaijan have ensued from both parties recently. The Azerbaijani Parliament ratified the treaty on June 21 2013 while the FYR Macedonian Parliament followed suit just a month later. The ratifications both come shortly after the signing of the treaty which was concluded in April this year.

September 30 2013

Montenegro: VAT treatment of promotional activities

Jelena Zivkovic, Eurofast Global The open character of the Montenegrin market and the emphasis on development of the country as a tourism destination, coupled with the presence of numerous foreign companies, has made promotional activities particularly interesting for both resident and non-resident companies.

September 30 2013

Mexico: closer scrutiny of international taxpayers coming

Oscar Molina, of the Mexican tax authorities, tells Ralph Cunningham he is prepared to challenge structures that do not keep sufficient profit in his country.

September 30 2013

Seven reasons to choose a boutique tax recruitment agency

When choosing a specialist recruitment agency, the size of the company can have a significant impact on how far that agency can be trusted to deliver the work, says Izabela Hollander-Bolton of IBH Executive

September 30 2013

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