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Publication article
1 January 2014
On 5 December 2013, the British government published upcoming changes to the UK tax regime. These upcoming changes will be of particular importance to the employers of expats, as they will target dual contract arrangements and offshore intermediary...
Publication article
1 January 2014
On 27 November 2013, the German government published its tax policy for the upcoming four years. While not containing concrete, imminent measures the policy is a valuable insight into Germany's tax system actively countering base erosion and profit...
Publication article
1 January 2014
Under Italian tax law, companies are obligated to provide the Italian tax authorities with a list of the assets the company provided for use by its private individual shareholders, as well as loans and capital the company has received from its...
Publication article
1 January 2014
The Finnish Supreme Administrative Court applied to the Court of Justice for the European Union’s Marks & Spencer doctrine to a cross-border merger involving tax deductible losses. The final losses were determined in accordance with the Finnish...
Publication article
1 January 2014
provide a periodic analysis at least every six months of the value of the issued financial instruments. 4. The last financial statements of the company must be certified by an auditing firm. 5. The financial instruments may only be sold to qualified...
Publication article
1 January 2014
Before 2009, non-resident companies directly holding German real estate were denied the higher depreciation rate of 3%. The Lower Fiscal Court of Cologne ruled that forcing non-resident companies directly holding German real estate to use the...
Publication article
16 September 2014
The legislation seeks to prevent profits being transferred to another group company by way of a payment of all, or a significant part, of the profits of a company. The legislation is primarily targeted at payments under derivative swap contracts but...
Publication article
16 September 2014
On 29 July 2014, the Chinese State Administration of Taxation issued an announcement ('ShuiZongBanFa 2014 No. 146') to strengthen its investigation on service and royalty charges from overseas related parties during the past ten years from 2004 to...
Publication article
16 September 2014
Since April 2012 secondary adjustments were treated as deemed loans, but this caused a lot of uncertainty and practical problems. This may be the reason that the Taxation Laws Amendment Bill, 2014 (Draft), includes that secondary adjustments shall...
Publication article
16 September 2014
Since the start of the OECD’s BEPS project, Ireland has been very supportive of all initiatives. Already in October 2013, the Irish government broadcasted a so-called international tax strategy statement. This document contained Ireland’s objectives...

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