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Tax Relief

Who you gunna call? The IRS, probably. This month, Ephraim Moss, co-founder of Expat Tax Professionals, mused on some interesting figures from the US Treasury Department that revealed an eye-opening number of US citizen expatriations (originally put together for the CNBC).

May 26 2016

Dutch ruling could open fiscal unity to non-EU parents

Heico Reinoud and Kuba Grabarz examine how a recent Court of Appeal judgment affects the way multinational companies can use advantageous Dutch fiscal unity rules.

May 26 2016

Deals of the month

See who has done the tax work on this month’s biggest deals

May 26 2016

Spain: Crossfire in the Spanish tax authorities

Vicente Bootello José Ignacio Ripoll In recent months we have been witness to a doctrinal battle still being fought by various administrative bodies regarding the interpretation of whether or not late-payment interest should be treated as a deductible expense for corporate income tax purposes.

May 26 2016

Cyprus: Cyprus and US conclude FATCA competent authority arrangement

Andri Christodoulou The governments of the US and the Republic of Cyprus have concluded an agreement aimed at improving tax compliance through mutual assistance in tax matters based on an effective infrastructure for the exchange of information.

May 26 2016

Poland: Tax law changes on the way in Poland

Paweł Mazurkiewicz The Polish government and parliament are in the process of preparing amendments to the tax laws, which are aimed at the introduction of new taxes and new procedures. Apart from the already enacted (and effective as of January 1 2016) tax on financial institutions, the government and legislature are working on the new proposals, which include:

May 26 2016

FYR Macedonia: FYR Macedonia ratifies double tax treaty with UAE

Elena Kostovska On April 1 2016, the FYR Macedonian parliament ratified the tax treaty signed with the UAE on October 26 2015. The ratification law was published in the Official Gazette No 63 of April 1 2016.

May 26 2016

Chile: Chile extends corporate income tax credit use

Lorenzo Gálmez Paula Silva While the 2014 Tax Reform Act, N° 20.780, limited the full use of corporate income tax credit (known in Chile as First Category Tax Credit) to foreign taxpayers who were tax residents of countries with which Chile had double tax treaties (DTT) already in force, the "Simplification" Tax Reform Act, N° 20.899 of 2016, extended such benefit to residents of countries with which Chile has signed a DTT even if they are not yet in force, though same conditions.

May 26 2016

Australia: Australian Budget increases heat on cross-border taxpayers and transactions

Jock McCormack The Australian Government continued attacking multinational tax avoidance with its 2016-2017 Federal Budget released on May 3 2016. The announced measures include a 40% diverted profits tax on large multinationals from July 1 2017, akin to the UK diverted profits tax.

May 26 2016

Norway: Interest limitation rules restrict freedom of establishment, ESA states

Trond Eivind Johnsen "Norway has failed to fulfil its obligations arising from Article 31 of the EEA Agreement", states the EFTA Surveillance Authority (ESA) in a letter of formal notice to the Norwegian Ministry of Finance dated May 4 2016. The reason is Norway's interest limitation rules combined with the group relief rules

May 26 2016

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