RSM Global

PROVIDING YOU WITH INSIGHT INTO DIFFERING RULES AND REGULATIONS

UNDERSTANDING EUROPE

As one of the most diverse regions in the world, Europe offers significant opportunities for business growth and expansion. However, the diversity of the region with varying currencies, regulations and stages of economic growth, can make Europe a very complex place for businesses to thrive.

With over 10,000 staff across the region, RSM assists businesses to anticipate and understand these complexities, in order to succeed in the largest consumer market in the world.

Europe: Freedom of establishment

1 April 2014
On 27 February 2014, the Advocate General (AG) of the European Court of Justice (ECJ) issued her opinion on the cases C-39/13, C-40/13 and C-41/13. These three cases were directed to the ECJ by the Dutch court in the light of prejudicial questions. 

Belgium: Foreign Tax Credits

1 March 2014
On 29 January 2014, the Belgian Constitutional Court ruled on the compatibility of the Belgian foreign tax credit rules with the Belgian constitution. The Constitutional Court ruled that denying the carry-forward or carry-back of an unused foreign tax credit is not unconstitutional. The same goes for not refunding an unused foreign tax credit.

Europe: Parent Subsidiary Directive

1 March 2014
On 25 November 2013, the European Commission (EC) proposed to change the European Parent Subsidiary Directive (PSD). The EC wishes to close certain loopholes in the PSD that multinationals may have started to use to avoid corporate taxes.

France: French Finance Bills

1 March 2014
The French parliament has approved the amended Finance Bill 2013 and the new Finance Bill 2014. The bills include changes to corporate taxation, individual taxation and indirect taxes. Some of these important measures are described below. Changes in corporate taxation

The Netherlands: Dividend withholding tax

1 March 2014
The Advocate General at the Court of Justice for the European Union (CJEU) recently published his opinion on two (joined) cases about Dutch entities distributing profits to their parent companies located on Curacao in 2005 and 2006.

The Netherlands: Substance Requirements

1 March 2014
As of 1 January 2014, financial service entities must report in their annual corporate income tax returns whether or not they meet the new substance requirements.

Mexico: Mexican legal framework - Year end tips

28 February 2014
2013 was a year full of changes in the business environment in Mexico. Perhaps the most significant one is derived from the changes made to the Mexican legal framework. Between 2013 and 2014 new legal provisions have been and will be enacted that will have great impact on the way we do business in Mexico. Appoint a “compliance officer”

Sweden: Personal Income Tax

1 February 2014
An individual is considered to be a resident for Swedish tax purposes if the individual has a home at his disposal in Sweden. Any individual without such a real home within Sweden can also be treated as a resident for Swedish tax purposes, provided the individual resides in Sweden permanently.

Finland: Dividend withholding tax

1 February 2014
On 25 September 2013, the Finnish Supreme Administrative Court (SAC) ruled that interest must be paid when refunding Dividend Withholding Tax (DWT) that has been levied incorrectly from dividends intended for foreign entities. This was already the case for DWT levied from dividends intended for Finnish entities.

Italy: Advance tax rulings & permanent establishments

1 February 2014
On 23 December 2013, the Italian government published a decree concerning the Italian advance tax ruling procedures.

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