RSM Global

Tax news

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

Russia: Review of the Russian Federal Legislation in the period 1 January 2015 up to and including 31 March 2015

13 May 2015
Changes in the procedure for calculating interest on borrowed fund 

Venezuela: Transfer Pricing

13 May 2015
From 1 January 2001, Venezuela changed its territorial income tax system to include non territorial income tax; in other words, a Worldwide Tax System.

Denmark: Record breaking Transfer Pricing adjustment in Denmark

13 May 2015
The Danish tax authorities have, for the third year in a row, increased the taxable income of multinational groups with a record-breaking amount. The latest years’ audit results in 20 billion DKK: The Danish tax authorities have, for the third year in a row, increased the taxable income of multinational groups with a record-breaking amount.

Germany: Qualification conflicts and Treaty overriding

13 May 2015
German domestic law requalifies rental and interest income into business income in cases where a business consists of two entities under common control or when the shareholder holds assets that are key for the business, privately.

France: Updated list of tax-abusive structures and schemes

13 May 2015
On 1 April 2015, the French tax authorities announced several measures aimed at improving legal certainty for individuals and businesses. To be more specific, the tax authorities published a list of practices and transactions that are deemed to be abusive:  

Czech Republic: New VAT rate as from 2015

13 May 2015
The Czech Ministry of Finance has announced a new second reduced VAT rate of 10%, applicable as of 1 January 2015 in the Czech Republic. As a result, the following three VAT rates are currently applicable in the Czech Republic:

Uruguay: Uruguay meets international standards of fiscal transparency

8 May 2015
In March 2015, the Ministry of Finance reported that the Global Forum on Transparency and Exchange of Information for Tax Purposes, the multilateral organisation in which international standards on transparency and tax cooperation are developed, approved unanimously the technical report referred to the Uruguayan case corresponding to Phase 2.  

Brazil: PIS/COFINS-Importation and PIS/COFINS on Financial Revenues

8 May 2015
In connection with a recent statement to increase revenue collection, the Brazilian Government published new rules related to PIS/COFINS. The main points are:

Albania: Ministry of Finance published instruction on Advance Pricing Agreements

15 April 2015
On 25 February 2015, the Ministry of Finance of Albania published an instruction on Advance Pricing Agreements (APA). In this instruction the various types of APA’s are defined, and the application process and conditions are comprehensively substantiated.  Types of APAs The following types of APA's are included in the instruction:

Norway: Carried Interest

15 April 2015
In a recent High Court decision – the “Herkules case” – it was concluded that carried interest should be considered employment income. The decision was appealed with the Supreme Court, but highlights the risk of structuring Norwegian management of private equity funds. The case comes as a follow up of previous cases related to brokers, where internal partnership pr

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