ITR Search | International Tax Review

South Africa: Constitutional validity of retrospective legislation

The recent High Court decision of Pienaar Brothers (Pty) Ltd v Commissioner for the South African Revenue, a highly important judgment dealing with the constitutionality of retrospective legislation, underscores the importance for taxpayers of participating in or at least being aware of the public consultation process around proposed tax amendments in order to be forewarned of pending changes.

October 26 2017

Poland: Debt push down no longer tax deductible from 2018

Acquisition of Polish companies used to be structured via an acquiring Polish entity (limited liability company or a joint stock company) which was debt financed. Both before and after the merger of the acquisition and the target the interest on debt was tax deductible. It was limited with debt to equity thin capitalisation that applied only to selected related party debt. Interest on non-related party debt (bank loans) was fully tax deductible.

October 26 2017

New Zealand: New Zealand to restate and reform trust law

In August 2017, the Trusts Bill was introduced in New Zealand's Parliament. The bill seeks to restate and reform New Zealand's trust law and is the first significant change in New Zealand's trust law in more than 60 years.

October 26 2017

Montenegro: Montenegro hikes VAT rate and amends excise duties

Montenegro has recently sharpened its focus on fiscal consolidation with a target to achieve budget surplus and to establish a declining trend in the level of public debt from 2019. On the revenue side, additional measures will be aimed at further harmonising the excise policy with the EU's rules. Additionally, the government is set to increase the standard VAT rate by two percentage points as of 2018, an adjustment which will not disturb the Montenegrin tax system.

October 26 2017

China: Modernised industry regulation, greater oversight, and a strengthened DTA network

In September and October 2017 a series of new and proposed rules sought to modernise industry regulation, give the public authorities greater oversight of payments and asset ownership, and strengthen China's network of international tax agreements.

October 26 2017

RIP: Freedom to expose the truth

I present this month's magazine to you with a heavy heart after hearing the sad news of fearless investigative journalist Daphne Caruana Galizia's murder.

October 26 2017

Andersen Global signs collaboration agreement with two firms in Ecuador

Andersen Global has established its presence in Ecuador, as part of its international revival, through a collaboration agreement with two leading firms, FIDESBURó and PROFILE.

Josh White, October 26 2017

Malta reviewing domestic tax law in preparation for ATAD

Like all EU member states, Malta is preparing to transpose the Anti-Tax Avoidance Directive into domestic law. Nicky Gouder and Luana Scicluna of ARQ Group discuss the changes businesses can expect.

October 26 2017

The EU’s misguided tax war on US companies

The European Union has released another state aid decision that targets a US multinational corporation. Joe Kennedy, senior fellow at the US Information Technology and Innovation Foundation who specialises in tax and regulatory policy, examines the global damage the EU’s actions could cause.

October 26 2017

Ireland: Budget 2018 maps route for tax modernisation

The Irish Minister for Finance made his annual budget announcement on October 10 2017. The budget contained a number of measures proposing amendments to domestic Irish tax law, most of which were in line with pre-budget expectations. In addition, as part of the budget package, the minister also published a paper on Ireland's international tax strategy and corporation tax review (the strategy paper), which provides valuable insight into the Irish tax policy agenda for the coming years.

October 26 2017

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