Search results for

Ilias Sakellariou Greece has always adopted a very broad interpretation of what it considers as royalties in the context of its double tax treaties (DTAs), based on specific observations and the reservation that it has expressed on Article 12 of the OECD Model Tax Convention.

Alvaro Pereira Mark Conomy Brazil's Federal Court of Curitiba has released a decision on the application of the new Brazilian controlled foreign corporation (CFC) rules on May 6 2016. The single court judgment, in relation to Process No. 5005596-52.2015.4.04.7000/PR, outlines that a Brazilian taxpayer may remove from the calculation of its corporate income tax (IRPJ) and social contributions (CSLL), results of its controlled foreign subsidiaries located in Argentina and Chile, until those results are effectively made available to the Brazilian controller.

The publication of annual financial statements (AFS) in the trade register is often neglected by Bulgarian trading enterprises.

Tax authorities could use blockchain, the technology most well-known for its use in bitcoin, to clamp down on tax evasion – particularly in the area of VAT.

Raphaël Glohr, partner at Deloitte in Luxembourg, and Michel Lambion, director at Deloitte in Luxembourg, examine the European Union’s implementation of the Voucher Directive, which aims to clarify and harmonise relevant VAT rules.

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.

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.

Read this month's special feature on Labuan IBFC

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.

Richard Asquith, vice president of global indirect tax at Avalara, provides an analysis of the revolutionary standard audit files for tax (SAF-T) filing requirements that are sweeping across Europe.