ITR Search | International Tax Review

EXCLUSIVE: Supreme Court of Norway rules in IKEA case

Norway has ruled in the IKEA Handel og Eiendom case involving more than $50 million in interest deductions on inter-company debt in a tax decision that could have implications for multinationals using the arm's-length principle.

October 26 2016

E-commerce: The global shift in taxation

Distance-selling regimes that impose a sales tax on digital goods and services are spreading across the globe. Joe Stanley-Smith looks at how these changes are being shepherded by the OECD.

Joe Stanley-Smith, October 26 2016

Ireland updates its international tax strategy

Ireland's annual budget statement was announced by the Minister of Finance on October 11 2016. The minister confirmed Ireland's commitment to the 12.5% corporation tax rate (a statement which has become a staple in recent budgets) and also confirmed that "nobody is asking for it to be changed".

October 26 2016

Romania: Romanian individual tax residency position

The enactment of the Romanian Fiscal Code in January 2016 brought significant changes to an individual's tax residency position. For the first ever time, the Romanian legal framework provides for a 'split year' residency.

October 26 2016

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

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