RSM Global

Tax news

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

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:

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.

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).

Netherlands: New decrees on legal mergers, split-ups and split-offs

18 March 2015
On 6 February 2015, the Dutch State secretary of Finance published new guidance regarding the application of articles 14a (split-ups and split-offs) and 14b (legal mergers) of the Dutch Corporate Income Tax Law 1969 (CIT Act).

Greece: Intragroup dividends withholding tax exemption

18 March 2015
Intragroup dividends paid or earned as of 1 January 2014 are exempt from local withholding tax if they meet the following criteria:

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.

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