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  • I've never been one for fine dining. Don't get me wrong, I love flavour, freshness and fancy food, but to be honest I find myself in the same boat as the tax authorities. Something can be intricately and expensively assembled and put in front of me ever so politely, but what I really crave at the end of the day is substance.
  • Tax incentives and tax relief for special geographical areas in Croatia are regulated by myriad acts and ordinances that are constantly changing and adjusting to the demands of the acquis communautaire. Whereas previously such relief was structured and destined for free trade areas, highlands and areas of special state care, now it is being categorised as a state incentive, subject to EU standards and requirements. The entrepreneurs who are conducting their business activities in the city of Vukovar or the so-called assisted areas (classified as 'Group 1' under the development index) are thus exempt from the payment of corporate income tax or – in the case of craftsmen or self-employed free professionals – personal income tax. Details and conditions for applying for such exemptions are elaborated further in the text.
  • Over the past decade, permanent establishments (PE) have emerged as one of the hottest topics of dispute during tax inspections in Italy and have also frequently been the subject of contention in the context of tax courts. This has applied especially in relation to the way foreign companies have opted to use the structure to set up their businesses in Italy (the so-called 'undisclosed PE'). And considering the operational impact that a PE risk may trigger, it has become even more crucial to evaluate the possible consequences on the supply chains of the new definitions and concepts brought about by the OECD's work in relation to the BEPS project (in particular, Action 7: Preventing the Artificial Avoidance of Permanent Establishment Status).
  • The Minister of Finance (MoF) issued MoF Regulation No. 35/PMK.010/2018 of 2018 concerning Granting of Corporate Income Tax Allowance (MoF Regulation 35) on April 4 2018, which replaced the old regulations issued in 2015 and 2016 stipulating the same. In general, MoF Regulation 35 provides terms that are arguably more beneficial to corporate taxpayers as compared to those under the old regulations. Note that 'corporate taxpayers' herein refers only to those making new investments in pioneer industries.
  • Companies, including those in the private equity sector, should consider the relevance of the PPT to their business operating models in the post-BEPS environment.
  • In a widely anticipated and important announcement, on March 27 2018, the Australian Treasurer, Scott Morrison, outlined a range of integrity measures to: (i) Tighten the rules on stapled structures; (ii) Limit certain tax concessions for foreign pension funds and foreign governments (including sovereign wealth funds); and (iii) Restrict thin capitalisation.
  • Mike Bernard, former Microsoft tax counsel, talks to ITR about his experience at Microsoft, how the tax department functioned, and how he will help MNEs use data to be audit-ready in his new role at Vertex.
  • The US Tax Cuts and Jobs Act and other countries’ responses to it, the BEPS project, various exchange of information agreements, incoming tax treaty changes and national elections are just a few of the obstacles ensuring that tax professionals have plenty of planning on their plates in 2018.
  • The OECD’s David O’Sullivan opened ITR’s Indirect Tax Forum by talking about the role which web companies can play in collecting VAT and GST. Subscribers and delegates can download his presentation – and those of other speakers, including the EU’s Maria Teresea Fábregas – here.
  • During 2017 and the first quarter of 2018, various developments have taken place in Cyprus as regards double tax agreements (DTAs), with a number of new DTAs, protocols and amending protocols being signed and coming into force.