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Ireland: Ireland confirms AT1 instruments treated as debt

Turlough Galvin Kevin Smith Ireland's Finance Bill 2015 (the Bill) was published on October 22 2015 and it contains new (previously unannounced) provisions on the Irish tax treatment of Additional Tier 1 (AT1) instruments. The Bill confirms that AT1 instruments qualifying as such under the Capital Requirements Regulations will be regarded as debt instruments.

December 15 2015

Switzerland: Switzerland is likely to remain a premier group financing location post-BEPS

Rene Zulauf Andreas Fross Globalisation has played an important role in the way multinational enterprises (MNEs) are structured today. Group financing is centralised at a regional or global level to benefit from numerous cost synergies, including taxes.

December 15 2015

Russia: Russian conduit companies – do your sub-holding companies have substance?

Anton Zykov Alexander Grinko Since the Supreme Commercial Court's ruling on November 15 2011 in the Severny Kuzbass case, Russian commercial courts have widely adopted the OECD Model Convention, commentaries on the articles of the Model Convention, and reports adopted by the OECD Council, as the basic framework documents that set out the general principles and approaches to avoiding double taxation.

December 15 2015

New Zealand: New Zealand introduces Bill to impose GST on cross-border services

Tim Stewart A Bill has been introduced to the New Zealand Parliament that, if enacted, will apply goods and services tax (GST) to remote services and intangibles (including e-books, music, videos and software) supplied by non-resident suppliers to New Zealand resident consumers.

December 15 2015

Poland: VATable and non-VATable transactions in Poland – allocation of input VAT

Marta Szafarowska Those dealing with VAT in other EU countries are surprised that, so far in Poland, taxpayers making both VATable transactions as well as activities that do not fall within the VAT regime, are entitled to deduct the whole amount of VAT resulting from purchases of goods and services where direct allocation to VATable and non-VATable activities is not possible.

December 15 2015

US Inbound: US issues new guidance on allocation of income

Jim Fuller David Forst Treasury and the IRS have issued new temporary § 482 regulations. While written from a US outbound perspective, they also can be important, perhaps even helpful, from an inbound perspective.

December 15 2015

Intangible contributions in the automotive industry under BEPS

In the fourth of a series on intangibles, Philip de Homont and Alexander Voegele, both of NERA Frankfurt, examine how to deal with contributions by many group companies.

December 15 2015

The Cunningham column: China gets ready to lead tax world in 2016

China will be at the forefront of BEPS implementation in 2016, as president of the G20. Ralph Cunningham says it is a big opportunity for a non-OECD member to shape the international tax system.

December 15 2015

Foreword

Pascal Saint-Amans and Grace Perez-Navarro comment on the impact the work on the BEPS Action Plan has made over the past two years and thank the staff of the Centre for Tax Policy and Administration (CTPA) at the OECD for their efforts.

December 15 2015

Action 2: Neutralising the effect of hybrid mismatch arrangements

John Peterson emphasises that common and coordinated action will be critical to the success of efforts to tackle cross-border hybrid mismatches.

December 15 2015

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