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  • Dentons has promoted José Ramón Vizcaino to partner in its Madrid office.
  • Freddy Karyadi Nina Cornelia Santoso On April 28 2017, the Directorate General of Tax (DGT) issued Circular Letter No. SE-11/PJ/2017 concerning the plan, strategy, and measurement of audit performance of 2017 (Circular Letter 11). The circular is essentially issued to increase tax audit effectiveness that will ultimately increase the results of tax audits and be used as a deterrent to promote tax compliance. The DGT stipulates that the 2017 tax audit will focus on, among others, the implementation of the tax amnesty programme. The DGT will differentiate tax audit treatment between taxpayers who have and those who have not joined the tax amnesty programme. For those who have not joined the tax amnesty programme, the DGT may conduct a tax audit for a tax period, part of a tax year or a tax year in which the tax stipulation has not expired. In the event that such a taxpayer is undergoing a tax audit, the tax auditor may also conduct asset tracing for any undisclosed assets in income tax annual tax returns.
  • Patrick Schrievers Mark de Vaan Since the introduction of BEPS Action 13, a lot of countries have implemented, or are implementing, new transfer pricing documentation obligations for multinational groups in their domestic law. Such obligations have also entered Dutch law and have effect from financial years beginning on or after January 1 2016. Dutch law, decrees and policy, covering country-by-country reporting (CbCR) and master and local filing, are in line with what was agreed by the OECD and G20. Based on these obligations, multinational companies with a consolidated group turnover of €750 million ($857 million) or more must file an annual CbC report. In addition, Dutch taxpayers that are part of a multinational group with a consolidated turnover of at least €50 million in the preceding year should prepare an OECD-style master and local file for transfer pricing and branch allocation documentation purposes.
  • Khoonming Ho Lewis Lu On May 9 2017, the State Administration of Taxation (SAT), together with five other government ministries and agencies, issued the Administrative Measures for Due Diligence Investigation of Financial Accounts of Non-Residents as Announcement 14 [2017].
  • Ignacio Rodríguez The Minimum Notional Income Tax (MNIT) is a sort of alternative minimum income tax and is payable by, among others, companies, partnerships and other business entities organised or established in Argentina (including branches of foreign companies, certain trusts, closed mutual funds, and so on).
  • Germany's Federal Constitutional Court has ruled that the German change-in-ownership rules relating to loss carryforwards partially infringe the constitution, and must be amended with retroactive effect.
  • Lewis Lu Curtis Ng The Hong Kong government has revised the concessionary tax regime for certain aircraft leasing activities to ensure it requires require real economic substance and activity in Hong Kong.
  • Des Kruger Anne Bennett Non-executive directors (NEDs) of South African companies are reacting with dismay to a ruling from the South African Revenue Service (SARS) requiring them to register and account for VAT on their directors' fees from June 1 2017.
  • When Indian Prime Minister Narendra Modi announced the launch of the country's goods and services tax to much fanfare at a glittering ceremony, he probably wasn't expecting international attention outside of the tax world.
  • Spanish electricity producers, including those using renewable systems, need to review their tax payments on the value of electricity output to determine if they may be eligible for a refund in the wake of court cases on the controversial tax.