Sponsored

The Federal Tax Administration has issued a new circular letter (number 37A), which confirms the existing practice of the majority of cantons for the deductibility of equity incentive expenses.

The New Zealand government is consulting on measures that would require the reporting of details of beneficial ownership of companies and limited partnerships on a public register.

Mexico’s alternative finance market has grown significantly. Regulators now face the challenge of setting rules that allow the industry to flourish, while in parallel trying to ensure they will have sufficient powers to adequately supervise such a constantly evolving space.

On April 16 2018, the draft Bill introducing a VAT group regime in Luxembourg was made public.

Following a public consultation on draft regulations designed to provide operational guidance on transfer pricing in line with the international evolution that has occurred at OECD level (the BEPS project), the Italian Ministry of Economy and Finance issued the Decree of May 14 2018 on the application of the arm's-length principle based on international best practices (published in the Official Gazette number 118 of May 23 2018).

The OECD BEPS initiative has introduced numerous likely challenges to transfer pricing structures defended through application of the transactional net margin method (TNMM). This article focuses on the economic analysis enhancements needed to make TNMM-type transfer pricing solutions sustainable in the future.

In recent years the Chinese government has progressively replaced administrative pre-approvals for various tax treatments and regulatory licences with tax authority record filing requirements. This has been coupled with more targeted and effective procedures for follow-up audit and review.

There have been a number of important Australian tax developments recently that affect offshore businesses/investors and their inbound investments into Australia.

Recently, the Income Tax Appellate Tribunal gave an important judgement regarding the creation of and attribution of profits to an agency permanent establishment (Agency PE) – Daikin Industries v ACIT ('ITA No 1623 of 2015 [New Delhi Income Tax Appellate Tribunal, May 28 2018]').