This content is from: Sponsored Ireland: Closing of the consultation on Ireland’s corporation tax code By Catherine O’Meara & Matheson & Trevor Glavey February 27 2018
This content is from: Sponsored Mexico: Lack of business purpose as factor in determining sham transactions A recent court ruling in Mexico has enabled the tax authorities to dive deeper into taxpayer affairs to determine whether transactions have real substance. Carlos Ramírez & Víctor Masón of Deloitte Mexico explain why ... By Deloitte Mexico February 27 2018
This content is from: Sponsored Poland: The CIT-8 return involving new transfer pricing obligations By Magdalena Marciniak & MDDP February 27 2018
This content is from: Sponsored US Outbound: New LB&I directives both change and clarify IRS transfer pricing procedures By Cameron Taheri & KPMG US & Mark Martin February 27 2018
This content is from: Sponsored Portugal: Personal income tax on cryptocurrencies: is the recent ruling a final take? The taxation of income had been unclear since the recent boom in cryptocurrency trading. The new ruling has come to the delight of tax authorities. By Garrigues Portugal & Tiago Cassiano Neves February 27 2018
This content is from: Sponsored Italy: Italian tax police, transfer pricing and business restructuring: still hot topic... By Barbara Scampuddu & Gian Luca Nieddu & Hager & Partners February 27 2018
This content is from: European Union EU consultation discloses views on digital economy taxation The European Commission has now published the outcome of its public consultation on fair taxation of the digital economy. The survey shows the majority of stakeholders favours an international discussion and believes ... By Lena Angvik & Sonja Caymaz February 26 2018
This content is from: South Africa South Africa takes aim at tax avoidance and thin capitalisation In the new South African budget, Finance Minister Malusi Gigaba drew attention to tax avoidance strategies, and vowed to crack down on excessive interest deductions and to strengthen tax authority governance. By Lena Angvik February 23 2018
This content is from: Transfer Pricing Denmark rules benchmark essential in transfer pricing documentation A recent decision by the Danish Tax Tribunal showed that benchmark analysis with comparable parties is one of the most important elements to be included in transfer pricing documentation in order to avoid taxable inco... By Lena Angvik February 23 2018
This content is from: United Kingdom EU digital tax rules could affect UK businesses post-Brexit The UK will need to decide on its approach to taxing the digital economy after Brexit. Adopting potential laws from the upcoming EU Commission’s digital tax proposal is one option, but implementing unilateral measures... By Lena Angvik February 22 2018
This content is from: Australia Fewer high-risk companies expected from ATO guidelines The Australian Taxation Office continues to seek closer engagement with large taxpayers as it releases guidelines for multinational companies to assess the risk of their related-party debt financing. By Lena Angvik February 16 2018
This content is from: Transfer Pricing Multinationals seek to mitigate CbCR cyber risks Cyber security is among the top concerns for taxpayers and tax authorities as country-by-country reporting is being rolled out in more than 40 countries. Some tax directors are now considering to think of the CbC repo... By Lena Angvik February 15 2018
This content is from: European Union EU vies with OECD digital economy taxation proposal The EU and the OECD are both setting out proposals for how to best tax companies in the digital economy. While EU sources say the two proposals could be similar, the OECD is worried doubling up could obstruct a harmon... By Lena Angvik February 14 2018
This content is from: United Kingdom Lack of grandfathering in diverted profits tax opens door for tough audits Corporates in the UK may see unexpectedly large bills if they are hit with a diverted profits tax charge, as the legislation does not grandfather pre-existing arrangements. By Lena Angvik February 12 2018
This content is from: United Kingdom Tom McFarlane joins transfer pricing team at Hogan Lovells Tom McFarlane now heads the EMEA transfer pricing team in London. By Lena Angvik February 12 2018
This content is from: Belgium Belgian CbCR burdened by tax technology Belgium may struggle to fulfil its CbC exchange commitments after technology trouble in the filing process, leaving non-resident affiliates that have relied on Belgian parties for filing unsure of what to do. By Lena Angvik February 08 2018
This content is from: India India breaks ground with nexus to tax digital business models India’s 2018 budget introduced the idea of digital permanent establishment as the country aims to modernise tax laws for the digital age. Companies are now waiting to see how profit attribution rules for digital PEs w... By Lena Angvik February 06 2018
This content is from: Albania Final week to enter for the European Tax Awards The deadline to submit for the European Tax Awards is fast approaching. Companies, firms and individuals working in jurisdictions across Europe should enter now. By Sonja Caymaz February 06 2018
This content is from: United States US MNEs plan investments with repatriated cash In dealing with the mandatory repatriation tax US multinationals have overcome the first wave of impact from the US tax reform. Now they are facing decisions over where to invest the money, with M&A and business model... By Lena Angvik February 05 2018
This content is from: Hong Kong SAR Hong Kong’s new transfer pricing rules bring PE and audit risks The introduction of transfer pricing legislation in Hong Kong will align the special administrative region with OECD standards, but could carry risks related to permanent establishments and audits. By Lena Angvik February 01 2018
This content is from: Poland MDDP promotes head of transfer pricing to partner Polish law firm MDDP has promoted Magdalena Marciniak, the head of its transfer pricing unit, to partner. By Lena Angvik February 01 2018
