Expert Guides

Transfer pricing adjustments – the current Irish landscape

The work of the OECD, the EU State aid investigations, public perception and the hunt for public funds by various Governments, mean that transfer pricing disputes will likely increase over the coming years

31/08/2017 Catherine O’Meara, Matheson, Ireland

International exchange of data in tax matters: a revolution is just around the corner

In the near future, international data exchange in tax matters will revolutionize taxation procedures in Germany and other countries

03/05/2017 Andreas Rodin, P+P Pöllath + Partners, Germany Maximilian Haag, P+P Pöllath + Partners, Germany

Canada’s Limited Response to BEPS

On March 22, 2016, the Minister of Finance tabled Canada’s 2016 federal budget (the 2016 Budget)

05/08/2016 Robert A Kopstein, Blake Cassels & Graydon, Canada Dan Jankovic, Blake Cassels & Graydon, Canada

The GCC Evolving Tax Landscape

The Gulf Cooperation Council (GCC) countries have in the past few years faced significant fiscal challenges, heightened by reduced revenues from their traditional oil and gas resources

04/08/2016 Reggie Mezu, Baker McKenzie Habib Al Mulla, United Arab Emirates

Doing Business in Nigeria From Taxation Perspective

Nigeria like most other countries that employ largely bureaucratic manual tax administration rather than a technology driven risk based approach have problems.

04/08/2016 Robert Ade-Odiachi, SIAO Partners, Nigeria

Reconsidering the figure of FICAP as a vehicle for private equity investments in Mexico

In view of the current macroeconomic conditions worldwide (specifically the uncertainty in certain economic regions such as Europe and Asia) it is possible to imagine that international investors might turn their interest to a country like Mexico, as one of the most stable developing countries in...

04/08/2016 Manuel E Tron, SMPS Legal, Mexico Federico Scheffler, SMPS Legal, Mexico

Brazil introduces ultimate beneficiary disclosure requirement

A normative instruction (NI) published on 9 May 2016 makes changes to the national registry of legal entities (CNPJ) for Brazilian and foreign legal entities, particularly concerning the disclosure of ultimate beneficiaries

04/08/2016 Marcelo Natale, Deloitte, Brazil Daniel Yamamoto, Deloitte, Brazil

Brazil, world champion in fiscal bureaucracy

According to a study published by the Brazilian Institute for Tax Planning (IBPT), the tax burden on the Gross Domestic Product (GDP) went, in 2014, from 35.04 per cent to 35.42 per cent

04/08/2016 Júlio M de Oliveira, Machado Associados, Brazil

Swiss Corporate Tax Reform III

Switzerland will replace its privileged tax regimes by new attractive and internationally accepted tax measures

04/08/2016 Walter H Boss, Bratschi Wiederkehr & Buob, Switzerland Stefanie Maria Monge, Bratschi Wiederkehr & Buob, Switzerland

Proposals for information exchange on advance rulings concerning cross-border tax issues, revised rules on transfer pricing documentation and the introduction of country-by-country reporting

The Swedish Ministry of Finance and the Swedish Tax Agency have drafted new rules regarding the mandatory automatic exchange of advance rulings concerning cross-border tax issues, revised rules on transfer pricing documentation and the introduction of country-by-country reporting in the spring of...

04/08/2016 Lennart Staberg, PwC, Sweden

Russia’s State Duma approves revised draft law introducing VAT on e-services

Russia’s State Duma approved the amended draft law introducing VAT on e-services in a third reading on 15 June 2016

04/08/2016 Oleg Berezin, Deloitte, Russia Estella Dzhantukhanova, Deloitte, Russia

Polish GAAR to Enter into Force on July 15, 2016

On May 13, 2016 Sejm, the lower chamber of the Polish Parliament, passed amendments to the 1997 Tax Code, introducing the General Anti-Avoidance Clause (GAAR)

04/08/2016 Janusz Fiszer, Gessel, Poland

New IP regime in Hungary

On 7 June 2016, the Hungarian parliament passed the tax bill that includes changes to the existing intellectual property (IP) regime, in line with action 5 of the OECD’s base erosion and profit shifting (BEPS) project (“Countering Harmful Tax Practices More Effectively”)

03/08/2016 Gabor Koka, Deloitte, Hungary Gabriella Kocsis, Deloitte, Hungary

German Real Estate Transfer Tax and Share Deals

Transactions concerning German real estate usually trigger Real Estate Transfer Tax (RETT) of 3.5% to 6.5% of the purchase price or the asset value

03/08/2016 Michael Best, P+P Pöllath + Partners, Germany Hardy Fischer, P+P Pöllath + Partners, Germany

The Danish courts set limits as the Danish tax authorities continue to challenge deductibility of business expenses

In recent years, the Danish tax authorities have significantly increased their attention on deducibility of business expenses

03/08/2016 Hans Severin Hansen, Plesner, Denmark

Exit Tax in Case of Outbound Cross-Border Mergers: Recent Austrian Tax Law Changes

The Austrian Reorganization Tax Act (Umgründungssteuergesetz) deals with the tax consequences of various types of corporate restructurings

03/08/2016 Niklas Schmidt, Wolf Theiss, Austria Cynthia Pfister, Wolf Theiss, Austria

New Zealand “Netflix tax” bill passed

The bill commonly referred to as the “Netflix tax” bill was passed by the New Zealand parliament on 13 May 2016 and will apply as from 1 October 2016

03/08/2016 Allan Bullot, Deloitte, New Zealand

India plugs capital gains exemption loophole under tax treaty with Mauritius

On 10 May 2016, India and Mauritius signed a protocol to amend the existing tax treaty which has been in force since 1982

03/08/2016 Rajesh Gandhi, Deloitte Haskins & Sells, India Utkarsh Trivedi, Deloitte Haskins & Sells, India Gaurav Chandak, Deloitte Haskins & Sells, India

The long awaited realignment: India Mauritius inks protocol amending tax treaty

At a low key event on Tuesday, May 10, 2016 at Port Louis, Indian and Mauritian government brought an end to the never ending speculation between the two sovereign; with regard to the bilateral tax treaty entered by them

03/08/2016 Aseem Chawla, Phoenix Legal, India Pranshu Goel, ASC Legal, India

Hong Kong enacted new law to attract corporate treasury operations

On 3 June 2016, the HKSAR Government gazetted the Inland Revenue (Amendment) (No. 2) Ordinance 2016 (the new law) that sought to attract multinational and mainland China enterprises to establish corporate treasury centres (CTCs) in Hong Kong by amending the Hong Kong Inland Revenue Ordinance (IRO)

03/08/2016 Tracy Ho, EY, Hong Kong

Corporate inversions: Recent developments

Corporate inversions are the hottest topic in US tax law. In a typical inversion, a US acquiring company combines with a smaller foreign target beneath a new foreign parent. An inversion is generally motivated at least in part by the acquirer's desire to save taxes.

29/05/2015 Michael L Schler, Cravath Swaine & Moore, US Christopher K Fargo, Cravath Swaine & Moore, US

Tax valuation of IPs in post-deal reorganisation

As part of Base Erosion and Profit Shifting Project (BEPS), OECD has recently issued a publication on transfer pricing aspects of intangibles. The topic of the publication is important, as during the past decades many countries have witnessed a shift from the capital intensive economy to the economy...

31/03/2015 Raimo Hietala, EY, Finland Toni Huotari, EY, Finland

Brazilian trends on cross border transactions

Understanding Brazilian taxation has always been a challenge not only for multinationals aiming at doing business in Brazil but also for Brazilian companies expanding their activities abroad. Different transfer pricing rules, different tax rules on profits earned overseas, broader concept of...

01/09/2014 Erika Yumi Tukiama, Machado Associados, Brazil

Building an MNC in need of tax advice

In most cases, multinational corporations (MNCs) do not come into existence overnight, and tax planning is not always the starting point, although some will argue that it should be. An MNC usually starts with a business idea, a new technology, or a new product, etc. and, hopefully, where the...

01/09/2014 Stanley Sherwood, Sherwood Associates, US

Canadian tax

The 2014 federal budget and draft legislative proposals released in 2014 (collectively, the "Proposals") contain a number of proposed amendments that, if enacted, will impact both inbound and outbound investments. In addition, the Federal Court of Appeal recently released an important decision...

01/09/2014 Michael Colborne, Thorsteinssons, Canada Michael McLaren, Thorsteinssons, Canada Tim Barrett, Thorsteinssons, Canada

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