ITR Search | International Tax Review

Cyprus: Cyprus and Latvia sign DTA

The details of the first agreement for the avoidance of double taxation (DTA) between Cyprus and Latvia became available in August 2016, providing information on the various applicable tax rates.

October 26 2016

US regulations crack down on earnings stripping

The US Treasury and Internal Revenue Service have finalised earnings stripping regulations that reduce the benefit of corporate inversions and limit the ability of companies to lower tax bills through transactions involving debt that does not support new US investment. The regulations also require large companies claiming interest deductions to document loans to and from affiliates.

Anjana Haines, October 26 2016

Businesses rush to prepare for UAE VAT

The United Arab Emirates is on target to implement its VAT regime on January 1 2018, but with the final VAT Law yet to be published, businesses face a tight deadline to make sure they have the tools to comply with the new system.

Anjana Haines, October 26 2016

Greece: Uncertain application of Greece’s network of double tax treaties

The history of Greek tax laws, as well as precedents established by tax disputes, have impacted the country's underlying financial crisis. Adding to the issues, the tax administration has once again begun imposing a special solidarity tax (mentioned in the relevant special tax law as a "contribution") on the foreign income of Greek tax resident individuals (initially, via Law 3986/2011). Under perhaps different names, the same may also be true for other countries, such as Cyprus.

Konstantinos Mavraganis, October 26 2016

Chile: Tax treatment for cloud computing services provided without a license

In June 2016, the Chilean tax authority (IRS) issued a private ruling for the first time regarding payments for the provision of cloud computing services that are not offered by granting a license.

October 26 2016

Switzerland: UK’s hybrid mismatch rules to impact Swiss entities

The UK's new legislation to tackle hybrid mismatches, which enters into force on January 1 2017, may impact certain Swiss principal structures that are benefitting from a so-called Circular No. 8 regime.

October 26 2016

Croatia: Croatian transfer pricing regulations

Although Croatia is not an OECD member country, the provisions of the relevant Croatian tax legislation are generally based on the OECD Transfer Pricing (TP) Guidelines.

October 26 2016

Investors and BEPS: A precarious balance

The OECD BEPS Actions will result in a higher effective tax rate (ETR) and cash tax liability for most multinationals, whereas investors will continue to strive for lower ETRs and cash tax liabilities in the companies they consider for investment. Keith Brockman looks at where the balance should be in this equation, and who should be the master negotiator.

October 26 2016

Nigeria’s insurance industry: An unfair tax burden

The insurance industry in Nigeria is fighting to reduce an unfair and overburdening tax liability. Adebayo-Begun Oluwatomisin, senior adviser at KPMG Nigeria highlights the big issues affecting the sector, from what is being done to address these challenges, to which other countries provide good structures that support their businesses.

October 26 2016

Build, buy or outsource: Withholding tax reclamation

Some investors and advisers still believe that the global withholding tax reclamation process is so complex and labour-intensive that it outweighs the advantages, but this is simply not true. Bill Salva, global business development manager at Goal Group looks at the options for reclaiming withholding tax.

October 26 2016

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