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What do companies look for in a holding jurisdiction?

The unrelenting global demand for transparency has created an unprecedented need for substance. Labuan International Business and Financial Centre (Labuan IBFC) examines how and where this need can be met in Asia.

August 23 2016

Germany: Domestic tax law provisions and Brexit

Alexander Linn Thorsten Braun German companies need to rely on EU law to distribute dividends to UK parent companies free of withholding tax. One obvious consequence of the Brexit would be that EU law, such as the Parent-Subsidiary Directive, would no longer apply. For German entities, this would mean increased withholding tax on dividends paid to UK holding entities since the Germany-UK tax treaty only reduces the rate to 5%.

August 23 2016

MNEs and Belgium attack EU Commission’s decision on excess profits tax rulings

BASF and at least four other multinationals are headed to the European Court of Justice arguing that competition commissioners acted beyond their powers in deciding that Belgium’s excess profits tax rulings constituted illegal state aid. The companies face billions of dollars in back taxes if they lose.

Anjana Haines, August 23 2016

Bosnia and Herzegovina: Non-residents subject to capital gains tax

Dajana Topic The amendments to the Corporate Income Tax Law of the Federation of Bosnia and Herzegovina (FBiH) entered into force on March 6 2016. The new updates are effective as of January 1 2016 and provide that non-resident companies are taxed on capital gains derived from the sale of shares, immovable property or interests in equity, unless otherwise provided by a tax treaty.

August 23 2016

Albania: Albania changes VAT exemption rules

Dorina Asllani Ndreka Albania's Ministry of Finance issued a Directive in May 2016 to change Directive No. 6, dated January 30 2015, 'On the value added tax in the Republic of Albania'. The Directive expands the range of financial transactions excluded and facilitates its implementation.

August 23 2016

Poland: Tax authorities reveal the outcomes of tax audits

Magdalena Marciniak There has been a growing interest in how tax authorities deal with transfer pricing issues. Both taxpayers and tax authorities have been paying special attention to this following the OECD's recommendations to tackle profit shifting to low or no-tax jurisdictions in its BEPS Action Plan.

August 23 2016

Canada: Mark-to-market available to non-financial institutions

Nancy Diep In a recent decision by the Federal Court of Appeal (FCA), it was confirmed that the adoption of mark-to-market valuation is not restricted to financial institutions for the purposes of computing income for Canadian tax purposes.

August 23 2016

Croatia: Amendments to the Croatian Corporate Income Tax Act

David Jakovljevic The Croatian Parliament approved the EU Parent-Subsidiary Directive (2011/96/EU) and subsequent amendments to it (2015/121/EU). It also passed amendments to the Croatian Corporate Income Tax Act (CIT Act) on May 13 2016, which was published in the Official Gazette no. 50/2016 and entered into force on June 9 2016.

August 23 2016

US elections: Presidential plans to halt corporate inversions

Donald Trump has said he will curb “job-killing corporate inversions” by reducing the US business tax rate from 35% to 15% if he becomes the next US President. Meanwhile, his rival Hillary Clinton plans to deter companies by levying an ‘exit tax’ on businesses moving overseas. Will either plan work? Caroline Byrne reports.

Caroline Byrne, August 23 2016

Australia: The aftermath of Australia’s federal election

Michael Yunan After a close election result, the Federal government has indicated that it will present its Budget legislation to parliament before the end of the year.

August 23 2016

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