ITR Search | International Tax Review

From principal to profit split

In the sixth in a series of articles on intangibles and finance, NERA Frankfurt’s Philip de Homont and Alexander Voegele show how to deal with low margins through a profit split system.

March 09 2016

Can BEPS provide a cure to the Kimberley Process blues?

Bernd Schlenther, senior manager at the South African Revenue Service (SARS), analyses governance initiatives relating to illicit flows, taking into account the recent impact of measures to counter base erosion and profit shifting (BEPS).

March 09 2016

Cyprus: Reduced withholding tax rate on dividends from Russia to Cyprus

Christiana Nicolaou On October 9 2015, the Russian Ministry of Finance (MoF) issued Letter No. 03-08-13/57909 to provide further clarification on the application of the reduced withholding tax rate on dividends in accordance with article 10 of the double tax treaty between Russia and Cyprus.

March 09 2016

State and local cooperation key to success of Chinese reform

The Chinese government published the long-awaited “Blueprint for Deepening the Reform of Collection and Administration Systems of State and Local Tax Administrations” on December 24 2015. In this article, Wang Jun, Commissioner of the State Administration of Taxation (SAT) explains how clarifying the roles and responsibilities of state and local tax administrations will help achieve a better tax system and make taxpayers happier.

March 09 2016

Canada: Canadian voluntary disclosure programme rises in popularity

Bill Maclagan Soraya Jamal In January 2016, the Canada Revenue Agency (CRA) released new statistics relating to Canada's voluntary disclosure programme (VDP).

March 09 2016

Chile: Chile’s new (not-so-)thin capitalisation rules

Sandra Benedetto Ignacio Burrull On September 29 2014, Law No. 20.780 was published in the Chilean Official Gazette (2014 Tax Reform), which introduced several modifications to the Chilean taxation system. However, on February 8 2016, Law No. 20.899 was published in the Official Gazette (2016 Tax Reform), which introduced modifications to the 2014 Tax Reform.

March 09 2016

Germany: German Federal Tax Court questions constitutionality of interest deduction limitation rule

Alexander Linn Thorsten Braun Germany's Federal Tax Court (BFH) referred a case to the Federal Constitutional Court (BVerfG) on February 10 2016 requesting a ruling on whether the interest deduction limitation rule violates the constitution (case ref. I R 20/15).

March 09 2016

Albania: Albania and Morocco sign tax treaty

Dorina Ndreka Albania and the Kingdom of Morocco preliminarily agreed on the need for an agreement on the avoidance of double taxation (DTA) back in 2012 when treaty negotiations commenced. The willingness to conclude such an agreement was reiterated in October 2014 during Albanian parliamentary officials' visit to Morocco. The treaty was finally signed during the visit of the Albanian Minister of Foreign Affairs to Morocco in October 2015.

March 09 2016

Corporate Tax Reform III in light of BEPS

Andreas Fross and Markus Reese of Deloitte analyse the latest Swiss corporate tax reform developments in the context of wider international tax reform efforts.

March 09 2016

Special features - March 2016

Read this month's special features for Intangibles and Switzerland

March 09 2016

Search results for