Financial services

How hedge funds and investors continue to strike the right note in aligning their interests

RSM, in collaboration with AIMA have issued their latest research ‘In Harmony – how investors continue to strike the right note in aligning their interests’, following the ‘In Concert’ paper which was published three years ago.

RSM posts record revenues as consulting services power growth

RSM has reported record global revenues of $5.37 billion for 2018

Understanding cybersecurity and the operational risks of cryptocurrency

The regulatory environment and the operational and security risks are vitally important when investing in cryptocurrencies. While the price fluctuation for bitcoin, a type of cryptocrrency, garnered significant public interest in 2017, many fundamental questions remain on this subject. Questions such as: What are cryptocurrencies? Why are they so popular? And what are the key risks and challenges of investing in them right now?

RSM breaks through US$5bn global revenue

RSM has delivered growth in every business line, reflecting RSM’s commitment to help middle market businesses fulfil their global ambitions. 2017 saw revenues rise by 5.6% to US$5.1bn.

RSM improves bank’s internal audit function

RSM was hired by the client to work alongside the internal audit manager of a bank, assisting with risk assessment, audit planning and a co-sourced execution of the annual internal audit plan under the oversight of the Bank’s audit committee.

Big data and the middle market

This article explores the use of Big Data by middle market businesses, whose adoption of these new technologies lags behind that of other sectors of the international business community.

132 businesses to compete at Grand Final of European Business Awards

132 businesses from 32 European countries are hoping to be named a winner in Europe’s biggest and toughest business competition, the European Business Awards, sponsored by RSM, at its Gala Event Final on 17 June in Milan, Italy.

How banks can increase cybersecurity risk management

The rise in advance persistent threats puts a spotlight on the vulnerability of the IT systems at many financial institutions—and intensifies the need to implement more robust security procedures to protect institutional assets.

Global economic review 2015/16: a new mediocre?

In October 2015, the International Monetary Fund (IMF) released its semi-annual World Economic Outlook. The IMF forecasts global economic output to grow by 3.6 percent in 2016, an improvement over world GDP growth rates in 2014 (3.4 percent) and 2015 (3.1 percent).

Rebuilding the Global Economy

Insights from an international comparative study of business ‘birth’ and ‘death’ rates.

The Transpacific Partnership

In June 2015 the U.S. Congress granted fast track authority to President Barack Obama, clearing the way for final negotiations of the Transpacific Partnership (TPP). The completion of the 12-member TPP would create a mega-regional zone representing 40 percent of global GDP and 26 percent of world trade.

Economic headwinds facing emerging markets

By most measures, emerging markets have outperformed developed economies since the Great Recession. Between 2010-14, emerging/developing economies posted averaged annual real GDP growth of 5.8 percent versus 1.8 percent in the advanced industrialised countries.

The Transpacific Partnership

USA: Businesses entering and investing into the United States through California — 2015

Non-US businesses face a variety of complex tax burdens when they choose to do business in the United States. A number of federal and state compliance and substantive tax obligations make doing business in the US potentially quite challenging, especially in California. However, many tax incentives exist that can mitigate the effect of some of these burdens.

Israel: Voluntary disclosure programme tackles the problem of unreported capital

If I had to summarise 2014 in one sentence, based on the economic and law-enforcement aspects, I would say that first of all, this year represents a ‘step up’ in the war that the Israel Tax Authority (ITA) leads to reduce the ‘black capital’ (unreported capital) phenomenon in an attempt to increase the circle of those obligated to submit financial statements.

Thailand: Permanent establishment risk in Thailand

Permanent establishment (PE) is a common term in international tax. The concept is very common in advice concerning cross-border business expansion. Many discussions between advisers and their clients will begin with a question along the following lines: “Do these activities to be undertaken create a PE risk?”

South Africa: The true cost to an employer of an expatriate in South Africa

With technology making the world a smaller place, it is understandable that large corporations expand their businesses into multiple jurisdictions as they continue to grow. However, setting up a new operation for an existing business in a foreign jurisdiction is not necessarily an easy task.

China: New Tax Reporting Obligations on Indirect Transfer of PRC Taxable Investments

Issue 23 - RSM Reporting

This edition features: Paul Druckman, CEO, IIRC Comments on IFRS and global accounting standards Our experts in... Australia Jane Meade and Daisy Yang report on the interpretation and application of IFRS 11 - Joint Arrangements

7 reasons why fund managers invest in Singapore

Despite a turbulent 2014, fund managers and sector analysts have expressed confidence in the resilience of Singapore’s investment environment for the future.

Issue 22 - RSM Reporting

This twenty-second edition features:

World Economic Outlook 2015

Economic Growth Trends

Hong Kong: Recent developments: Exchange of Information

In 2014, Hong Kong signed seven Tax Information Exchange Agreements (TIEAs) with the US and six Nordic jurisdictions. The signing of the TIEAs marks a new era of Exchange of Information (EOI) in Hong Kong.

Hungary: New EKAER reporting obligations

The Electronic Road Transportation Control System (EKAER) will help the tax authority in tracking every product transported in Hungary. The purpose of the system is to ensure no goods are put into circulation in Hungary that have not been previously reported to the Hungarian Tax and Customs Authority.

Mexico: Deduction for expenses apportioned from non-Mexican companies

On 10 October 2014, Mexico’s federal tax authority, the Servicio de Administracion Tributaria (SAT), published a package of miscellaneous tax rules (the “October 10 Rules”) that included guidance on various Mexican tax provisions.

Transatlantic Trade and Investment Partnership

In February 2013, the European Union (EU) and the United States (U.S.) commenced negotiations for a Transatlantic Trade and Investment Partnership (TTIP). The proposed pact would create the world’s biggest free trade area.

Issue 21 - RSM Reporting

This twenty-first edition features:

China: Corporate Income Tax Incentives

In order to encourage investment in certain areas in the People’s Republic of China, the Ministry of Finance (MOF) and the State Administration of Taxation (SAT) jointly published the notice Caishui 2014 No.

USA: New global tax and information reporting regimes create risks and burdens for businesses

Emboldened by the plethora of new legislation and guidance passed by the United States, many countries are considering implementing a standardised global information reporting (GIR) system.

Europe: The Mini One Stop Shop for e-services, broadcasting and telecom services

In January 2015 the VAT legislation providing for the place of taxation for e-services, broadcasting and telecom services will change. Although the actual change in legislation will be minimal, it will have a substantial impact on the providers of these services from a VAT compliance perspective.

Hungary: Advertisement Tax

Act XXII of 2014 on Advertisement Tax enters into force on 15 August 2014. The new public burden does not only concern the publishers of press products and commercial television channels.

Hong Kong: Effects of the international tax framework

The globalisation and development of the digital economy has fostered continuous growth of cross-border transactions. As different countries adopt different tax regimes, taxpayers may avoid taxation in their home countries by pushing activities abroad to low or no tax jurisdictions.

Issue 20 - RSM Reporting

This twentieth edition features: Our experts in UAE Baasab B. Deyb discusses insurance law - the journey so far and the way forward Martyn Jones, President of the ICAEW Discusses how to restore trust in the accounting and auditing profession globally

Issue 19 - RSM Reporting

This nineteenth edition features:

New Zealand: Tax Risk and IRD Compliance for Multinationals

In late 2013, the IRD released their Multinational Enterprises Compliance Focus Document. This document outlines the various areas the IRD will be focusing on for the next 12 months with regards to multinational enterprises (MNEs). This article summarises the must read sections of the document.

US / Canada: Investing in Canadian ULCs by US LLCs

For many years, the US-Canada Income tax treaty (the “Treaty”) did not grant treaty benefits to US Limited Liability Companies (“US LLCs”) because, in the view of the Canadian government, LLCs were not US tax residents since they are typically exempt from US tax1.

Israel: Changes in Taxation of a Controlled Foreign Corporation

On 25 December 2013, the Amendment of the Income Tax Ordinance Law (the “Law”) was published. As part of the Law, significant changes were made to some of the provisions of Section 75B of the Income Tax Ordinance (the “Ordinance”), dealing with the taxation of a controlled foreign corporation (the “CFC”).

Europe: How European VAT impacts US companies

When US companies deal with value added tax “VAT” challenges in Europe, whether newly established or well established, they often fall into the same avoidable traps.

Australia: Company PE Income may not be exempt from tax

Australia’s tax law exempts from tax foreign income derived by a company “in carrying on a business, at or through a permanent establishment (“PE”)”. Capital gains are also exempt from tax where “the company used the asset wholly or mainly for the purpose of producing foreign income in carrying on a business at or through a PE”.

An Introduction to Islamic Finance

Islamic finance is an emergent series of financial products that have been developed to meet the requirements and constraints of people that would like to follow the Shari’ah law. Islamic finance is a term that reflects financial business that is not contradictory to the principles of Shari’ah.

The Mini-Bond Market in Italy

The Italian economy was severely affected by the deepest recession since the Second World War. Amid a fiscal consolidation programme to reduce the country’s debt, Italy continues its quest to rekindle GDP growth.

Europe: Changes to Parent Subsidiary Directive

On 25 November 2013, the European Commission proposed to amend the European Parent Subsidiary Directive (PSD). Corporate tax avoidance has been at the top of the political agenda of EU and non-EU countries alike for over a year. Likewise, the G20 as well as the G8 have emphasized the urgency of countering corporate tax avoidance.

Australia: Domestic ship and aircraft tax

Australia’s domestic tax law imposes a 5% tax on amounts paid to foreign owners or charterers of ships or aircraft for the carriage of passengers, live-stock, mail or goods shipped in Australia (section 129 of the Income Tax Assessment Act, 1936). Section 129 can apply irrespective of where the passengers or goods are discharged.

Hong Kong: Inland Revenue Amendment Bill – Exchange of Information (EOI)

The Inland Revenue (Amendment) Bill (the Bill) was passed by the Legislative Council on 10 July 2013. It provides the legal framework to liberalise the Exchange of Information (EOI) regime in Hong Kong and enable Hong Kong to comply with the latest international standard of tax transparency. Difference between CDTAs and TIEAs

USA: Interest-Charge Domestic International Sales Corporations

An interest-charge domestic international sales corporation (IC-DISC) can be a powerful tax savings opportunity for many companies exporting products. An IC-DISC is a domestic corporation that primarily engages in foreign sales and exporting activity. Many years ago, the U.S. government created this law as a means to promote U.S.

Issue 18 - RSM Reporting

This eighteenth edition features:

Republic of Ireland: An Update

1. General economic update

Hungary: Final tax package 2014

As it was apparent from the proposal put forward in October that the volume of changes brought by the tax package of 2014 is altogether less significant than that of similar packages of the previous years.

Issue 17 - RSM Reporting

This seventeenth edition features:

USA: Withholding under US FATCA rules delayed

On 12 July 2013, the IRS issued Notice 2013-43 (the notice) that extends the date on which Foreign Account Tax Compliance Act (FATCA) withholding is to begin to 1 July 2014.

Mexico: Changes in Mexico's Federal Labour Law

On 1 December 2012, important changes in Mexico’s Federal Labour Law (the 2012 amendments) came into effect.

Germany: Tax Law Update

On 29 June 2013, numerous changes to the German tax law were published in the Federal Law Gazette and are applicable as of that date unless indicated otherwise. The changes in the law mainly concern the areas below. Correspondent taxation extended to dividends

Hong Kong: Beneficial Ownership

This article aims to provide you with the salient points of Circular 165. 1. Circular 601

Australia: Investment Manager Regime

On 4 April 2013, the Government released exposure draft legislation and explanatory materials which propose to implement the third and final element of the Investment Manager Regime (IMR) as announced by the Government on 16 December 2011. Context of amendments

Uruguay: Benefits of Uruguayan Trusts

Trusts in Uruguay are ruled under Law 17,703 which was published on 4 November 2003.

United Kingdom: Information Exchange Agreements

Whilst governmental attacks on tax avoidance seem to be rarely out of the financial news, the UK Government is also tackling tax evasion by entering into information exchange agreements with a number of tax havens, many of which are British Crown Dependencies.

Peru: Tax Benefit with 'technical assistance'

According to the general rule in Peruvian Income Tax (IT) Law, services rendered by non-resident individuals are subject to a 30% withholding income tax (WHT) rate. However, services that qualify as ‘technical assistance’ are levied with a 15% WHT rate applied on the Peruvian source income.

Issue 29 - IFRS News In Brief

This twenty-ninth edition features: Publications & Announcements Discussion paper for a new conceptual framework open for comment until 14 January 2014 IFRS Interpretations Committee - Latest Decisions Summary

Issue 28 - IFRS News In Brief

This twenty-eighth edition features: Publications & Announcements

Issue 16 - RSM Reporting

This sixteenth edition features:

Issue 27 - IFRS News In Brief

This twenty-seventh edition features: Publications & Announcements

Issue 26 - IFRS News In Brief

This twenty-sixth edition features: Publications & Announcements

Issue 25 - IFRS News In Brief

This twenty-fifth edition features: Publications & Announcements

Issue 15 - RSM Reporting

This fifteenth edition features:

USA: New regulations modify rules governing outbound transfers

On 18 March 2013, the IRS and Treasury published final, temporary and proposed regulations under Sections 367 and 12481 that address the treatment of outbound transfers of property by US corporations and other matters (“2013 Regulations”).

Netherlands: Five questions about aggressive tax planning

In recent months, there have been several reports by journalists into the tax affairs of multinational corporations resulting in public anger and accusations of tax avoidance.

Australia: Transfer Pricing: Tax Laws Amendment Bill

Further to the release of the Treasury’s exposure draft in mid-November, the Government has now introduced into Parliament stage two of the transfer pricing reforms, the Tax Laws Amendment (Countering Tax Avoidance and Multinational Profit Shifting) Bill 2013.

United Kingdom: New Controlled Foreign Company rules

The UK’s new Controlled Foreign Company (CFC) legislation is effective for all accounting periods beginning on or after 1 January 2013. This represents a timely wholesale revision of the rules as over the last few years there has been numerous revision to the rules in reaction to various recent Court of Justice of the European Union cases.

Hungary: Allowances for special enterprise zones

From 1 January 2013, the scope of tax allowances available to companies operating in special or free enterprise zones was extended in a number of tax types.

Issue 24 - IFRS News In Brief

This twenty-fourth edition features: Publications & Announcements Proposal for amendments to IAS 39 and IFRS 9 open for comment until 2 April 2013 International Accounting Standards Board - Latest Decisions Summary

Issue 23 - IFRS News In Brief

This twenty-third edition features: Publications & Announcements Proposal for amendments to IAS 36 open for comment until 19 March 2013 Proposed IFRS Taxonomy 2013 open for comment until 18 March 2013 IFRS Interpretations Committee - Latest Decisions Summary

Prospects for the World Economy 2013

The previous edition of RSM Talking Points ‘Prospects for the World Economy’ in September 2011 noted the following trajectory of the global economy: Weak GDP growth in the advanced industrialised countries burdened by the overhang of public and private debt left by the global financial crisis; robust growth in emerging markets that came out of the global downturn w

Issue 14 - RSM Reporting

This fourteenth edition features:

Non-EEA Investment and Entrepreneurship in Ireland

The Republic of Ireland is experiencing a slow recovery from the global credit crisis. Following a 10 percent GDP contraction in 2008-10, Ireland’s economy grew by 1.4 percent in 2011. Amid the global economic slowdown and the ongoing Euro crisis, the Irish economy is projected to grow by just 0.4 percent in 2012, rising to 1.1 percent in 2013.

United Kingdom: Proposed statutory residence test

In June 2011, the UK Government launched a consultation document on the introduction of a statutory residence test which the government proposed to introduce in April 2012. This has now been delayed until 6 April 2013. The response to this consultation has recently been issued providing greater clarification.

Transfer Pricing: OECD Discussion Draft: Transfer pricing aspects of intangibles

On 6 June 2012, the OECD published the first discussion draft for the revision of chapter VI of its transfer pricing guidelines.

Australia: Living Away From Home Allowance

In an earlier edition of Border Crossing - 1st Quarter 2012 - we reported on significant and adverse changes to the Living Away From Home Allowance (LAFHA) provisions. Those changes have now been legislated, with effect from 1 October 2012.

United States of America: The application of the US FATCA rules to International Investment Funds

In July 2009, the United States Department of Justice announced that it had reached a settlement with Swiss bank UBS under which the bank agreed to disclose the identities of over 50,000 US customers who used UBS accounts to commit US federal tax evasion.

Argentina: Termination of Argentina-Spain double taxation treaty

On 29 June 2012, the Argentine government notified Spain that it had terminated the Argentina-Spain tax treaty for the Avoidance of Double Taxation (the treaty).

Issue 13 - RSM Reporting

This thirteenth edition features:

Value added by Internal Control

Results of a European survey

Netherlands: New German-Netherlands tax treaty

On 12 April 2012, Germany and the Netherlands signed a new tax treaty and protocol. The new tax treaty avoids double taxation and prevents fiscal evasion with respect to taxes on the income of residents. Furthermore, it regulates and improves the position of frontier workers. The new tax treaty has not yet been ratified.

Italy: Investment Funds Tax and Capital Gains Changes

Introduction A new investment funds tax regime has been enacted in Italy meaning investment funds are no longer subject to tax on an accrual basis. Investors are instead taxed on a cash basis. Furthermore, from 1 January 2012 withholding tax and substitutive tax on interest, dividends and capital gains will be set at 20%.

USA: Proposed FATCA regulations

On 8 February 2012, the IRS issued proposed regulations providing rules pursuant to the Foreign Account Tax Compliance Act (FATCA). The proposed regulations are generally consistent with the guidance set out in prior Notices. However, there are significant modifications and refinements.

UK: Worldwide Debt Cap

Worldwide debt cap rules were introduced as an extension to the UK thin capitalisation rules to ensure that UK companies bear their fair share of group debt. It applies to accounting periods beginning on or after 1 January 2010.

Malta: High Net Worth Individuals Rules

The High Net Worth Individuals Rules (the Rules) have recently been introduced to attract high net worth foreign individuals to take up residence in Malta and take advantage of the beneficial rate of tax. The Rules apply to both EU and third country nationals and will run in parallel to the current Residents Scheme Regulations.

Issue 12 - RSM Reporting

This twelfth edition features:

China: Overseas Listed Companies ‘Share-based Incentive plans’

On 20 February 2012, the PRC State Administration of Foreign Exchange (“SAFE”) issued Circular Huifa [2012] No.7 – ‘Notice regarding certain issues related to foreign exchange administration for individuals employed by domestic companies participating in share-based incentive plans of overseas listed companies’ (“Circular [2012] 7”).

Issue 11 - RSM Reporting

This eleventh edition features:

South Africa: Transfer Pricing – A Significant Change

With effect from 1 October 2011, South African Transfer Pricing legislation was significantly changed by the implementation of an amended Section 31 to the Income Tax Act 58 of 1962 (”the Act”). The section has now further been amended in terms of the Taxation Laws Amendment Bill 19 of 2011 introduced by the Minister of Finance on 25 October 2011.

Australia: Removal of FBT Concessions for Foreign Executives

The Australian Government’s latest revenue raising measures are again targeting international businesses. The ‘Living away from home’ allowance and other related benefits have been denied concessional tax treatment for international employees along with increased substantiation requirements for all others. Background

USA: Foreign Investment in U.S. Real Estate

Is there a “best” way for a foreign individual to own U.S. real estate? When planning to acquire U.S. real estate, foreign individuals have a number of ownership alternatives to consider each of which offers its own advantages and disadvantages. There are other items a foreign investor should consider when evaluating the most advantageous method for holding U.S.

Commercial Developments in MERCOSUR

Since its creation in 1991, MERCOSUR (acronym in Spanish for Mercado Común del Sur or Common Market of the South) has been developing at an uneven pace.

Australia: Cross-border transfer pricing reforms

On 24 May, the Government introduced into Parliament the first piece of draft legislation in its reform of Australia’s transfer pricing provisions.

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Accounting standards. Industry regulations. Ever-evolving tax rules. New legislation.