RSM Global

Tax news

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

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

Europe: Tax Transparency Package to combat corporate tax avoidance

15 April 2015
Currently, it is at the discretion of Member States to decide whether tax rulings might be relevant to other Member States. The Tax Transparency Package includes measures for Member States to automatically exchange information on their tax rulings.

Germany: New ordinance on the 'attribution of income to permanent establishments' published

15 April 2015
Under the 'Authorised OECD Approach' (AOA) the profit attributed to a permanent establishment (PE) should be in line with what the PE would have earned under arm's length conditions, i.e. as if it were a separate and independent entity, engaged in the same or similar activities, under similar circumstances.

United Kingdom: Budget for 2015/2016 – Business taxation

15 April 2015
On 18 March 2015, the Chancellor of the Exchequer presented the Budget for 2015-16 to the Parliament. Details of the Budget relating to business taxation are summarised below. Corporation Tax Rate The Corporation Tax Rate is reduced to 20% from 2015 to 2016.

Italy: Black lists for cost deduction and CFC regime amended

15 April 2015
On 1 April 2015, the Ministry of Economy and Finance issued a press release announcing two Ministerial Decrees amending the black list for cost deduction and the black list for the application of the Controlled Foreign Companies (CFC) regime.

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:

Italian voluntary disclosure for individuals resident in Ita

1 April 2015
On 15 December 2014, the Italian Parliament approved the 'voluntary disclosure' procedure (Law n. 186/2014).

Cyprus: Alternative Investment Funds (AIFs)

18 March 2015
In July 2014, Cyprus harmonised its legislation in an effort to modernise its legislation on investment fund products in accordance with the EU directives.

Belgium: Introduction of the liquidation reserve

18 March 2015
On 1 October 2014, the former Belgian government increased the withholding tax on liquidation proceeds from 10% to 25%. Under certain conditions companies were allowed to benefit from a transitional regime resulting in a 10% withholding tax rate.

France: French 2015 Finance Bill and 2014 amended Finance Bill: Group Regime

18 March 2015
Following the judgment by the Court of Justice of the European Union (CJEU) on 12 June 2014 regarding the Dutch tax consolidation regime, the French tax consolidation regime has recently been modified.

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