RSM Global

Tax news

Newsletters from the RSM Tax Centre of Excellence, covering recent developments in taxation around the world.

OECD: OECD releases public comments received on discussion drafts on cost contribution arrangements of BEPS – Action 8

15 June 2015
On 1 June 2015, the OECD published the comments it has received on this discussion draft. In the past, the OECD had invited comments from interested parties on a discussion draft on revisions to Chapter VIII of the Transfer Pricing Guidelines on Cost Contribution Arrangements (work that relates to Action 8 of the OECD’s BEPS Action plan).

Germany/Netherlands: Treaty between Germany and Netherlands – details

15 June 2015
On 15 May 2015, the Netherlands ratified the Germany–Netherlands Income Tax Treaty 2012. This new treaty will replace the Germany–Netherlands Income and Capital Tax Treaty of 1959. The Treaty is in line with the OECD Model tax treaty. The maximum withholding tax rates included in the treaty are:

Netherlands/OECD: Impact of changes of OECD Model Commentary with respect to the articles 15 and 17

4 June 2015
On 23 April 2015, clarification on the impact of the changes of the OECD Model commentary on articles 15 and 17 was published in a special Decree (effective 2 May 2015). The Decree provides guidance with respect to termination payments and on the interpretation of the term 'personal activities' of artist and sportsmen.  

Macedonia: Changes to the Corporate Income Tax law

4 June 2015
According to the last changes on the Corporate Income Tax law (Official Gazette of the Republic of Macedonia no. 112/14 from 25/07/2014), the obligation for paying corporate income tax (CIT) on net income is restored as from the fiscal year 2014. The CIT rate remains 10%.

Europe OECD: The OECD published the revised discussion draft on Action 7

4 June 2015
On 15 May 2015, the OECD released a revised discussion draft on Action 7. The revision is a follow-up to the discussion draft on Action 7 of 31 October 2014, which addressed a number of PE avoidance strategies and potential strategies to deal with these.

Poland: Proposed legislation on Country by Country reporting

4 June 2015
Poland proposed legislation on Country by Country (CbC) reporting and related transfer pricing reporting obligations. The proposed legislation reflects the reporting obligations as included in Action 13 of the OECD’s initiative on Base Erosion and Profit Shifting. To be more specific, Poland has introduced thresholds for the Local File, Master File and CbC-report.

Europe: European Commission publishes strategy on the Digital Single Market

4 June 2015
The European Commission (EC) published its strategy on the Digital Single Market on 6 May 2015. The strategy includes 16 initiatives to be delivered by the end of 2016 and is built on three pillars: Access, Environment and Economy & Society.

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

20 May 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

20 May 2015
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

20 May 2015
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?”

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