Tax

Stay on top of tax changes.

If you’re a global business juggling the complex and diverse tax rules of multiple markets, it can be hard to stay on top. We offer in-depth, up-to-date knowledge of the relevant local rules and regulations. Through collaboration with our tax professionals across all relevant jurisdictions, we are able to provide you with seamless solutions.

We give you practical, commercially-focused and socially responsible advice from our most experienced tax experts. Together, we’re dedicated to finding the best possible tax solutions for your business, while always acting with the highest level of integrity and concern for your reputation.

G20 and OECD: The future of the global tax system

The OECD recently issued a Statement on a “Two Pillar Solution to Address the Tax Challenges...
11 October 2021
G20 and OECD: The future of the global tax system

The Future of Mobility Q&A

During our webinar on Global Mobility, our experts answered your questions surrounding what the...
23 August 2021
The Future of Mobility Q&A

The future of mobility

With the pandemic putting the issue of employee mobility front and centre, what does its future...
20 July 2021
The future of mobility

Post-pandemic M&A outlook - why we should be cautiously confident

Post-pandemic M&A outlook - why we should be cautiously confident...
22 June 2021
Post-pandemic M&A outlook - why we should be cautiously confident

Family offices in a virtual world

The traditional model of a family office setting up in a bricks and mortar space and hiring the...
12 May 2021
Family offices in a virtual world

Re-sculpting the tax landscape

Rob Mander discusses the changes in the global tax landscape and how consumer trends, combined with...
22 April 2021
Re-sculpting the tax landscape

OECD Guidance on Transfer Pricing implications for taxpayers

The recent OECD guidance around transfer pricing provides clarification for taxpayers on the...
30 March 2021

Transfer pricing in COVID times – an interim report

RSM experts discuss the international impact of the global pandemic on transfer pricing. The...
24 March 2021
Transfer pricing in COVID times – an interim report

RSM's Global Capabilities

Against the backdrop of a global health crisis, socio-political unrest, climate change, technology...
1 February 2021

COVID-19 and Transfer Pricing: Year-end adjustments

Michael Kratz and Juan Dosal consider the Transfer Pricing implications of actions taken to combat...
27 January 2021
COVID-19 and Transfer Pricing: Year-end adjustments

2021: It’s time to reimagine Tax

RSM International Tax expert, Rob Mander reflects on 2020 and explains why 2021 will be another...
19 January 2021
2021: It’s time to reimagine Tax

Paying for the Pandemic—Are Increased Taxes the Answer?

Conversations have already started about how the increased government expenditures to support...
8 September 2020
Paying for the Pandemic—Are Increased Taxes the Answer?

Restructuring business operations to reimagine a new way forward

The COVID-19 crisis is creating tremors that are being felt, on an international scale, by...
26 August 2020
Restructuring business operations to reimagine a new way forward

How private wealth can be the key to unlocking the lockdown

In the strange new reality of the COVID-19 world, one person’s challenge could become someone...
13 August 2020
How private wealth can be the key to unlocking the lockdown

International VAT Update – July 2020

Breaking VAT news from RSM’s experts around the world, including updates from Australia, New...
21 July 2020
International VAT Update – July 2020

Thinking Outside the Box to Revitalise the Global Economy

The global economy is facing the worst downturn in more than a century. Rob Mander, RSM...
1 July 2020
Thinking Outside the Box to Revitalise the Global Economy

Government Tax Incentives and COVID-19: The next stage of thinking

In these now very different times of globalisation and mass world travel, the business world is...
26 May 2020

COVID-19 update - Indirect tax, Netherlands

Covid-19 is disrupting business across the world requiring tax authorities to implement rules and...
21 May 2020
Covid-19 update - Indirect tax, Netherlands

COVID-19 update - Indirect tax, Germany

Covid-19 is disrupting business across the world requiring tax authorities to implement rules and...
21 May 2020
COVID-19 update - Indirect tax, Germany

COVID-19 update - Indirect tax, Spain

Covid-19 is disrupting business across the world and requiring tax authorities to implement rules...
21 May 2020
Covid-19 update - Indirect tax, Spain

COVID-19 update - Indirect tax, Switzerland

Covid-19 is disrupting business across the world requiring tax authorities to implement rules and...
21 May 2020
Covid-19 update - Indirect tax, Switzerland

COVID-19 update - Indirect tax, Czech Republic

COVID-19 is disrupting business across the world requiring tax authorities to implement rules and...
21 May 2020
COVID-19 update - Indirect tax, Czech Republic

COVID-19 update - Indirect tax, UAE

Covid-19 is disrupting business across the world requiring tax authorities to implement rules and...
21 May 2020
Covid-19 update - Indirect tax, UAE

COVID-19 update - Indirect tax, UK

Covid-19 is disrupting business across the world requiring tax authorities to implement rules and...
21 May 2020
COVID-19 update - Indirect tax, UK

COVID-19 update - Indirect tax, Brazil

Covid-19 is disrupting business across the world requiring tax authorities to implement rules and...
21 May 2020
COVID-19 update - Indirect tax, Brazil

COVID-19 international tax news – Global Employer Services

As part of a webinar series, International Tax Leader Rob Mander, speaks to RSM US’s Global...
29 April 2020
COVID-19 international tax news – Global Employer Services

Coronavirus – A global plan for a global challenge

The global impact of coronavirus aligned with the fact that different countries are at different...
31 March 2020
Coronavirus – A global plan for a global challenge

Covid-19 - International tax update

The COVID 19 situation is changing rapidly and governments and tax administrations are moving...
18 March 2020
Covid-19 - International tax update

International VAT Update: January 2020

Breaking VAT news from RSM's experts around the world...
29 January 2020
International VAT Update: January 2020

Value Added Tax Changes in Poland

From 1 November 2019, Polish tax authorities will be introducing significant changes in value added...
9 August 2019

International VAT Update: February 2019

Breaking VAT news from RSM's experts around the world, including updates from  the European...
4 February 2019

RSM posts record revenues as consulting services power growth

RSM has reported record global revenues of $5.37 billion for 2018...
28 January 2019

International VAT Update: June 2018

Breaking VAT news from RSM's experts around the world, including updates from Portugal, Norway...
5 June 2018

International VAT Update: March 2018

Breaking VAT news from around the world, including updates from the European Union, France, Italy...
5 March 2018

RSM breaks through US$5bn global revenue

RSM has delivered growth in every business line, reflecting RSM’s commitment to help middle...
15 January 2018

BEPS and beyond: tax issues to watch out for

When it comes to tax affairs, the biggest fear among clients is of committing an offence by...
16 November 2017

International VAT Update - November 2017

Breaking VAT news from around the world, including updates from the European Union, Romania...
10 November 2017

Mapping out your approach to BEPS

A guest blog by Rob Mander, International Tax Services, RSM . The international tax systems of the...
16 October 2017

European tax base dividing German industry and politics ahead of elections

Germany finds itself in an unusual scenario in handling the proposed European Common Consolidated...
22 September 2017

The gig economy isn’t holding back and the middle market shouldn’t either

With companies like Deliveroo and Uber bedding into our lives, the gig economy has revolutionised...
29 August 2017

International VAT Update – August 2017

Breaking VAT news from around the world, including updates from the Netherlands, Hungary...
11 August 2017

Tax complexity fuels uncertainty, but middle market firms can untangle the mess

Tax complexity is a challenge that is particularly acute for middle market businesses who lack the...
22 May 2017

International VAT Update – May 2017

Breaking global VAT news, including updates from the EU, the Arabian Gulf, Russia, Italy, UK...
16 May 2017

EU toughens stance on middle size enterprises

Ken Almand, Head of Transfer Pricing at RSM UK, looks at plans by the EU to impose stricter...
28 March 2017

Indirect Tax Update - January 2017

Breaking news from the RSM Indirect Tax Group, including updates from the GCC, EU, Netherlands...
31 January 2017

RSM Spain merges with TGG Legal, expanding its tax and legal practise

RSM Spain has merged with TGG Legal, an established law firm with a growing tax practice. The...
30 November 2016

Indirect Tax Update - October 2016

Breaking news from the RSM Europe VAT Group, including updates from the EU, UK, Netherlands...
28 October 2016

The BEPS Puzzle: Is it fitting together?

BEPS is like a puzzle. At least, it is puzzling when you stop and think about how it’s all going...
27 July 2016

Indirect Tax Update - July 2016

Breaking news from the RSM Europe VAT Group, including updates from the UK, Germany, Norway...
15 July 2016

Indirect Tax Update - April 2016

Breaking news from the RSM EU VAT Group, including updates from the European Union, UK...
26 April 2016

Indirect Tax Update - February 2016

This edition of the RSM EU VAT Group's Indirect Tax Update includes Netherlands, Switzerland...
17 February 2016

BEPS - The calm before the storm

In October 2015, two and a half years of frenetic activity culminated in the release of the Final...
12 February 2016

Global Tax News

RSM has teamed up with Euromoney to produce a survey, helping to reveal the views of global tax...
10 February 2016

European Commission presents anti-tax avoidance package

On 28 January 2016, the European Commission (EC) presented its EU Anti- tax Avoidance Directive, a...
2 February 2016

OECD announces further action to target international businesses

Tax avoidance by large businesses is a topic that continues to attract attention, with governments...
24 October 2015

The Evolution of Tax: a fifty-year perspective

A thought-leadership paper analysing the future evolution of the tax landscape, benchmarked against...
5 October 2015

Speed is key for global logistics company

Case study details   Client: One of the largest providers of warehousing services in the United...
5 October 2015

Global manufacturer relies on trusted relationships

Case study details   Client: A global manufacturer and distributor, with over 55,000 products...
5 October 2015

The Transpacific Partnership

In June 2015 the U.S. Congress granted fast track authority to President Barack Obama, clearing the...
23 September 2015

Thailand: Permanent establishment risk in Thailand

Permanent establishment (PE) is a common term in international tax. The concept is very common in...
20 May 2015

South Africa: The true cost to an employer of an expatriate in South Africa

With technology making the world a smaller place, it is understandable that large corporations...
20 May 2015

China: New Tax Reporting Obligations on Indirect Transfer of PRC Taxable Investments

Non-US businesses face a variety of complex tax burdens when they choose to do business in the...
20 May 2015

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

Non-US businesses face a variety of complex tax burdens when they choose to do business in the...
20 May 2015

Israel: Voluntary disclosure programme tackles the problem of unreported capital

If I had to summarise 2014 in one sentence, based on the economic and law-enforcement aspects, I...
20 May 2015

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

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

Norway: Carried Interest

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...
15 April 2015

Europe: Tax Transparency Package to combat corporate tax avoidance

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...
15 April 2015

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

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...
15 April 2015

United Kingdom: Budget for 2015/2016 – Business taxation

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...
15 April 2015

Italy: Black lists for cost deduction and CFC regime amended

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...
15 April 2015

Albania: Ministry of Finance published instruction on Advance Pricing Agreements

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...
15 April 2015

Italian voluntary disclosure for individuals resident in Ita

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

Cyprus: Alternative Investment Funds (AIFs)

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

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

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...
18 March 2015

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

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...
18 March 2015

Greece: Intragroup dividends withholding tax exemption

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

Diversion of profits tax update

HMRC has provided an insight into its policy thinking and the implications of the proposed new “Google tax”...
13 January 2015

Mexico: Deduction for expenses apportioned from non-Mexican companies

On 10 October 2014, Mexico’s federal tax authority, the Servicio de Administracion Tributaria...
19 December 2014

Hong Kong: Recent developments: Exchange of Information

In 2014, Hong Kong signed seven Tax Information Exchange Agreements (TIEAs) with the US and six...
19 December 2014

Hungary: New EKAER reporting obligations

The Electronic Road Transportation Control System (EKAER) will help the tax authority in tracking...
19 December 2014

RSM tax leaders expect minimal change to corporate tax rates across the world, despite G20 and OECD reform movement

The global tax system was built for an industrial age dominated by western powers but it is no longer fit for an economy driven increasingly by the internet, which is changing commerce, public...
12 December 2014

Warning shot fired at multinationals

The UK Government has announced details of their crowd pleasing measure dubbed “the Google tax”. But not everyone is smiling. Baker Tilly, RSM International member firm in the UK, reviews...
11 December 2014

Minimal change to corporate tax rates expected in spite of global tax infrastructure reform

The majority of tax advisers expect corporate tax rates to remain relatively unchanged over the...
8 December 2014

Nicaragua: Self-transfer of Value Added Tax (VAT)

The figure of the self-transfer of the Value Added Tax (VAT) applies when general services are provided or when the enjoyment or benefit is obtained from the use of goods by natural resident...
10 November 2014

Chile: Chilean Tax Reform

This change in taxation for companies has generated a significant slowdown in economic growth (current 5% down to 2% in the future). The gradual change in company income tax (20% in 2013) will be as...
10 November 2014

Venezuela: Exchange Trilogy in force in Venezuela

The exchange rate established by 'CENCOEX' is fixed and is set at 6,30 bolívares (Bs.) per U.S. dollar. It is applicable to items such as medicines, food, housing, education and any other item...
10 November 2014

Honduras: Double Taxation on dividend income

On 28 March 2010, the National Congress of Honduras passed a law called “Strengthening of Income, Social Equity and Rationalization of Public Spending Law” contained in decree No. 17-2010...
10 November 2014

Uruguay: Financial Inclusion Law

On 29 April 2014, Law No. 19,210 (or Financial Inclusion Law) was approved. The Law aims to promote access to banking services and the use of electronic means of payment, such as debit card, credit...
26 October 2014

Transfer Pricing News: Dutch State secretary of Finance on the arm's length principle

Recently the Dutch State secretary of Finance reacted through a public letter on the statement ‘The OECD’s Arms Length Principle, which is based on comparable market prices that do not really...
16 September 2014

Transfer Pricing News: China investigating service and royalty charges of past 10 years

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...
16 September 2014

Transfer Pricing News: Ireland OECD BEPS

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...
16 September 2014

Transfer Pricing News: UK legislation on countering avoidance schemes involving the transfer of corporate profits

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...
16 September 2014

Transfer Pricing News: Secondary adjustments again deemed to be treated as dividend or capital contributions in South Africa

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...
16 September 2014

USA: New global tax and information reporting regimes create risks and burdens for businesses

Emboldened by the plethora of new legislation and guidance passed by the United States, many...
1 September 2014

Europe: The Mini One Stop Shop for e-services, broadcasting and telecom services

In January 2015 the VAT legislation providing for the place of taxation for e-services, broadcasting and telecom services will change. Although the actual change in legislation will be minimal, it...
1 September 2014

Hungary: Advertisement Tax

Act XXII of 2014 on Advertisement Tax enters into force on 15 August 2014. The new public burden does not only concern the publishers of press products and commercial television channels...
1 September 2014

Hong Kong: Effects of the international tax framework

The globalisation and development of the digital economy has fostered continuous growth of cross-border transactions. As different countries adopt different tax regimes, taxpayers may avoid taxation...
1 September 2014

China: Corporate Income Tax Incentives

In order to encourage investment in certain areas in the People’s Republic of China, the Ministry of Finance (MOF) and the State Administration of Taxation (SAT) jointly published the notice...
1 September 2014

Panama: Still on grey listing

At the end of 2009, the Panamanian government adopted a national policy with the purpose of being excluded from the OECD grey listing...
26 August 2014

Argentina: Unconstitutionality of the Minimum Presumptive Income Tax. New pronouncement of the Supreme Court of Justice

The Supreme Court ruled, once again, that the Minimum Presumptive Income Tax in the Diario Perfil SA c/AFIP-DGI case is unconstitutional, in line with the June 2010 ruling in the Hermitage SA case...
26 August 2014

Transfer Pricing News - Malaysia: Disclosure requirement in Income Tax return

A new item has been included in the Income Tax Return for the Year of Assessment 2014 which requires the taxpayer to indicate whether transfer pricing documentation has been prepared by the taxpayer...
14 July 2014

Transfer Pricing News - The Netherlands: New Decrees on Advance Pricing Agreements

The State Secretary of Finance published new decrees that provide guidance on the various aspects of the regime that covers the Advance Pricing Agreement (APA) and replace the decrees of 2004...
14 July 2014

Transfer Pricing News - Australia: Revenue Authorities serious about driving down SME compliance work?

Following the recent release of draft rulings and practice statements by the Australian Taxation Office (ATO) relating to the new transfer pricing legislation in Australia, the ATO recently invited...
14 July 2014

Transfer Pricing News - Slovakia: New developments in Transfer Pricing in Slovakia

The Income Tax Act (ITA) has brought about a number of important changes that affect transfer pricing. In connection with the amendment to the OECD Transfer Pricing Guidelines in July 2010, the...
14 July 2014

Transfer Pricing News - Mexico: Pro rata cost allocation

Following a ruling of the Mexican Supreme Court of Justice on 19 March 2014, pro rata payments made outside of Mexico to non-residents are deductible – given that certain conditions are met...
23 June 2014

Transfer Pricing News - OECD: Base Erosion and Profit Shifting

On 26 May 2014, the OECD held a webcast giving an update on the progress of the BEPS project. During this webcast the spokesmen of the OECD, Pascal Saint- Amans, declared the two-year BEPS project...
23 June 2014

Transfer Pricing News - Denmark: Transfer Pricing corrections

On 31 March 2014, the Danish tax authorities published their Transfer Pricing report for 2013. The report contains an overview of transfer pricing corrections made by the Danish tax authorities. In...
23 June 2014

Transfer Pricing News - Australia: Transfer Pricing Guidance Package

On 16 April 2014, the Australian Taxation Office (ATO) published its Transfer Pricing Guidance Package. It contains two draft taxation rulings and two draft transfer pricing statements. These...
23 June 2014

Europe: OECD BEPS

The first action of the Base Erosion and Profit Shifting (BEPS) Action Plan consists of addressing the tax challenges of the digital economy. On 24 March 2014, the OECD released a discussion draft...
17 June 2014

Germany: Transfer Pricing

European countries are increasingly being confronted with the problem of double taxation of profits resulting from business relations with their associated enterprises based in so-called BRICS...
17 June 2014

Italy: Company assets revaluation

Law No. 247/2013 allows Italian companies that prepare their financial statement in accordance with the Italian Standard Accounts to revaluate the assets recorded in the financial statement as of 31...
17 June 2014

Italy: Compliance

n 1 January 2014, a new law entered into force providing additional regulations for the offsetting of tax credits relating to income taxes, withholding taxes, substitute taxes and the Regional Tax...
12 June 2014

Chile: Tax Reform in Chile

In March 2014, the recently elected President of Chile submitted a Bill to Congress with the goal of performing several changes through a structural tax reform to generate revenues. This reform is...
8 May 2014

Venezuela: Taxation Regime on Dividends

According to the provisions in the Income Tax Law, only those dividends arising from profits generated from 1 January 2001 shall be taxed. This means that dividends arising from profits prior to 1...
8 May 2014

El Salvador: Minimum Income Tax payment of 1% declared unconstitutional

By the end of 2011, the Salvadoran Income Tax Law was modified by, amongst other things, requesting companies to pay their income tax based on the higher of (a) 30% of net profit or (b) 1% of annual...
8 May 2014

Nicaragua: New Tax Law in Nicaragua

On 1 January 2013, the Government of Nicaragua passed Law Nº 822: 'CONCERTATION TAX LAW'(CTL). This Act and its regulations contain important changes in the tax regime...
8 May 2014

Peru: Double Taxation Treaties: Mexico, Korea, Portugal and Switzerland

On 27 and 28 December 2013, the Peruvian Congress approved four International Tax Treaties to avoid double taxation (Tax Treaties) signed by Peru with Mexico, Korea, Portugal and Switzerland...
8 May 2014

Belgium: VAT

On 3 March 2014, the Belgian Council of Ministers issued a press release concerning the new turnover threshold under which small businesses and associations qualify for VAT exemption. The turnover...
1 April 2014

Israel: Changes in Taxation of a Controlled Foreign Corporation

On 25 December 2013, the Amendment of the Income Tax Ordinance Law (the “Law”) was published. As part of the Law, significant changes were made to some of the provisions of Section 75B of the...
1 April 2014

Germany: Treaty override provision

On 11 December 2013, the German Federal Tax Court (FTC) submitted the question to the Federal Constitutional Court (FCC) whether the treaty override provision (article 50d (10) of the Personal...
1 April 2014

Europe: How European VAT impacts US companies

When US companies deal with value added tax “VAT” challenges in Europe, whether newly established or well established, they often fall into the same avoidable traps...
1 April 2014

Europe: Freedom of establishment

On 27 February 2014, the Advocate General (AG) of the European Court of Justice (ECJ) issued her opinion on the cases C-39/13, C-40/13 and C-41/13. These three cases were directed to the ECJ by the...
1 April 2014

Australia: Company PE Income may not be exempt from tax

Australia’s tax law exempts from tax foreign income derived by a company “in carrying on a business, at or through a permanent establishment (“PE”)”. Capital gains are also exempt from...
1 April 2014

Europe: EU Savings taxation

On 10 March 2014, the European Commission issued MEMO/14/172 (Memo) to answer frequently asked questions about the EU Savings Directive and the Savings Taxation Agreements with non-Member States. In...
1 April 2014

New Zealand: Tax Risk and IRD Compliance for Multinationals

In late 2013, the IRD released their Multinational Enterprises Compliance Focus Document. This document outlines the various areas the IRD will be focusing on for the next 12 months with regards to...
1 April 2014

United Kingdom: Crypto Currencies (bitcoins)

Bitcoins have received their fair share of attention over the past couple of months. The volatility of the market price for bitcoins makes for a lot of potential profits. Therefore, it is not...
1 April 2014

US / Canada: Investing in Canadian ULCs by US LLCs

For many years, the US-Canada Income tax treaty (the “Treaty”) did not grant treaty benefits to US Limited Liability Companies (“US LLCs”) because, in the view of the Canadian government...
1 April 2014

France: French Finance Bills

The French parliament has approved the amended Finance Bill 2013 and the new Finance Bill 2014. The bills include changes to corporate taxation, individual taxation and indirect taxes. Some of these...
1 March 2014

The Netherlands: Dividend withholding tax

The Advocate General at the Court of Justice for the European Union (CJEU) recently published his opinion on two (joined) cases about Dutch entities distributing profits to their parent companies...
1 March 2014

The Netherlands: Substance Requirements

As of 1 January 2014, financial service entities must report in their annual corporate income tax returns whether or not they meet the new substance requirements...
1 March 2014

Belgium: Foreign Tax Credits

On 29 January 2014, the Belgian Constitutional Court ruled on the compatibility of the Belgian foreign tax credit rules with the Belgian constitution. The Constitutional Court ruled that denying the...
1 March 2014

Europe: Parent Subsidiary Directive

On 25 November 2013, the European Commission (EC) proposed to change the European Parent Subsidiary Directive (PSD). The EC wishes to close certain loopholes in the PSD that multinationals may have...
1 March 2014

Costa Rica: New Transfer Pricing legislation

On 13 September 2013, the Ministry of Finance published Decree 37898-Hthat establishes new legislation on transfer pricing for Costa Rican taxpayers. Much of the legislation is common to that used...
28 February 2014

Mexico: Mexican legal framework - Year end tips

2013 was a year full of changes in the business environment in Mexico. Perhaps the most significant one is derived from the changes made to the Mexican legal framework. Between 2013 and 2014 new...
28 February 2014

USA: Cross Border Tax Enforcement and FATCA

The U.S. government continues to view offshore tax evasion as a significant loss of potential tax revenue. As a result, the government has been increasing its international enforcement efforts and...
28 February 2014

Uruguay: Income Tax Exemption for marketing merchandise of foreign origin

According to legislation in force in Uruguay, activities by foreign entities outside Uruguay; and those with goods in transit or deposited in customs facilities, port facilities, bonded warehouses...
28 February 2014

Argentina: Taxation of gains from the transfer of shares and dividends

Significant amendments have been introduced to Income Tax regulations, extending the tax scope to include certain financial gains, that were exempt from income tax and establishing an additional tax...
28 February 2014

United Kingdom: Tax Treaties

On 27 December 2013 the protocol to the UK–India tax treaty entered into force. As a result of this protocol, several provisions of the treaty are altered, e.g. the recognition of partnerships for...
1 February 2014

Sweden: Personal Income Tax

An individual is considered to be a resident for Swedish tax purposes if the individual has a home at his disposal in Sweden. Any individual without such a real home within Sweden can also be treated...
1 February 2014

Finland: Dividend withholding tax

On 25 September 2013, the Finnish Supreme Administrative Court (SAC) ruled that interest must be paid when refunding Dividend Withholding Tax (DWT) that has been levied incorrectly from dividends...
1 February 2014

Greece: Thin capitalisation rules

On 31 December 2013, the Greek parliament approved an amendment to the thin capitalisation rules. Greek thin capitalisation rules apply to all types of loans. This includes intragroup loans as well...
1 February 2014

Italy: 2014 Budget

On 27 December 2013, the Italian 2014 Budget was approved by the Italian parliament as well as published in the official gazette. The 2014 Budget contains several changes, some of which may affect...
22 January 2014

Germany: Corporate income tax

In 2013 the German legislator renewed section 14, par. 1, no 5 of the German Corporate Tax Act (GCTA). The new rule limits the utilisation of tax losses in fiscal unities (the German group taxation...
22 January 2014

Luxembourg: Upcoming tax policy

In December 2013, the new Luxembourg government announced its political program for the upcoming years. The announcement contains several direct and indirect tax measures...
22 January 2014

Italy: Compliance

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...
1 January 2014

Hungary: Final tax package 2014

As it was apparent from the proposal put forward in October that the volume of changes brought by the tax package of 2014 is altogether less significant than that of similar packages of the previous...
1 January 2014

Italy: New financial instruments

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...
1 January 2014

Europe: Changes to Parent Subsidiary Directive

On 25 November 2013, the European Commission proposed to amend the European Parent Subsidiary Directive (PSD). Corporate tax avoidance has been at the top of the political agenda of EU and non-EU...
1 January 2014

Australia: Domestic ship and aircraft tax

Australia’s domestic tax law imposes a 5% tax on amounts paid to foreign owners or charterers of ships or aircraft for the carriage of passengers, live-stock, mail or goods shipped in Australia...
1 January 2014

Germany: Updated tax policy

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...
1 January 2014

Hong Kong: Inland Revenue Amendment Bill – Exchange of Information (EOI)

The Inland Revenue (Amendment) Bill (the Bill) was passed by the Legislative Council on 10 July 2013. It provides the legal framework to liberalise the Exchange of Information (EOI) regime in Hong...
1 January 2014

Finland: Cross-border mergers

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...
1 January 2014

USA: Interest-Charge Domestic International Sales Corporations

An interest-charge domestic international sales corporation (IC-DISC) can be a powerful tax savings opportunity for many companies exporting products. An IC-DISC is a domestic corporation that...
1 January 2014

Germany: Depreciation of real estate

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...
1 January 2014

United Kingdom: Upcoming tax policy

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...
1 January 2014

Republic of Ireland: An Update

1. General economic update...
1 January 2014

Spain: 2014 Budget

On 26 December 2013, the Budget for Spain’s fiscal year 2014 was published in the official gazette. It contains several new tax measures as well as the extension of existing measures that are to...
28 December 2013

International Tax Reform: The Drive to Close Tax Loopholes in the OECD

In September 2013, the leaders of the G20 countries meeting in St. Petersburg endorsed the OECD’s...
1 September 2013

Mexico: Changes in Mexico's Federal Labour Law

On 1 December 2012, important changes in Mexico’s Federal Labour Law (the 2012 amendments) came into effect...
1 August 2013

Hong Kong: Beneficial Ownership

This article aims to provide you with the salient points of Circular 165. 1. Circular 601...
1 August 2013

Australia: Investment Manager Regime

On 4 April 2013, the Government released exposure draft legislation and explanatory materials which propose to implement the third and final element of the Investment Manager Regime (IMR) as...
1 August 2013

Germany: Tax Law Update

On 29 June 2013, numerous changes to the German tax law were published in the Federal Law Gazette and are applicable as of that date unless indicated otherwise. The changes in the law mainly concern...
1 August 2013

United Kingdom: Information Exchange Agreements

Whilst governmental attacks on tax avoidance seem to be rarely out of the financial news, the UK Government is also tackling tax evasion by entering into information exchange agreements with a number...
1 August 2013

Peru: Tax Benefit with 'technical assistance'

According to the general rule in Peruvian Income Tax (IT) Law, services rendered by non-resident individuals are subject to a 30% withholding income tax (WHT) rate. However, services that qualify as...
1 August 2013

USA: Withholding under US FATCA rules delayed

On 12 July 2013, the IRS issued Notice 2013-43 (the notice) that extends the date on which Foreign Account Tax Compliance Act (FATCA) withholding is to begin to 1 July 2014...
1 August 2013

RSM becomes lead sponsor of European Business Awards 2013/14

Since their inception in 2007 the European Business Awards have become one of the most engaging and best recognised business awards programmes in the world...
5 March 2013

USA: New regulations modify rules governing outbound transfers

On 18 March 2013, the IRS and Treasury published final, temporary and proposed regulations under Sections 367 and 12481 that address the treatment of outbound transfers of property by US...
1 March 2013

Netherlands: Five questions about aggressive tax planning

In recent months, there have been several reports by journalists into the tax affairs of multinational corporations resulting in public anger and accusations of tax avoidance...
1 March 2013

Australia: Transfer Pricing: Tax Laws Amendment Bill

Further to the release of the Treasury’s exposure draft in mid-November, the Government has now introduced into Parliament stage two of the transfer pricing reforms, the Tax Laws Amendment...
1 March 2013

United Kingdom: New Controlled Foreign Company rules

The UK’s new Controlled Foreign Company (CFC) legislation is effective for all accounting periods beginning on or after 1 January 2013. This represents a timely wholesale revision of the rules as...
1 March 2013

Hungary: Allowances for special enterprise zones

From 1 January 2013, the scope of tax allowances available to companies operating in special or free enterprise zones was extended in a number of tax types...
1 March 2013

The confusion over tax avoidance

Tax avoidance and evasion have become hotly debated topics during the global financial crisis as governments have sought to maximise tax revenues as part of their deficit reduction drives...
19 December 2012

Transfer Pricing: OECD Discussion Draft: Transfer pricing aspects of intangibles

On 6 June 2012, the OECD published the first discussion draft for the revision of chapter VI of its transfer pricing guidelines...
1 October 2012

Australia: Living Away From Home Allowance

In an earlier edition of Border Crossing - 1st Quarter 2012 - we reported on significant and adverse changes to the Living Away From Home Allowance (LAFHA) provisions. Those changes have now been...
1 October 2012

United States of America: The application of the US FATCA rules to International Investment Funds

In July 2009, the United States Department of Justice announced that it had reached a settlement with Swiss bank UBS under which the bank agreed to disclose the identities of over 50,000 US customers...
1 October 2012

Argentina: Termination of Argentina-Spain double taxation treaty

On 29 June 2012, the Argentine government notified Spain that it had terminated the Argentina-Spain tax treaty for the Avoidance of Double Taxation (the treaty)...
1 October 2012

United Kingdom: Proposed statutory residence test

In June 2011, the UK Government launched a consultation document on the introduction of a statutory residence test which the government proposed to introduce in April 2012. This has now been delayed...
1 October 2012

Netherlands: New German-Netherlands tax treaty

On 12 April 2012, Germany and the Netherlands signed a new tax treaty and protocol. The new tax treaty avoids double taxation and prevents fiscal evasion with respect to taxes on the income of...
1 June 2012

Italy: Investment Funds Tax and Capital Gains Changes

Introduction A new investment funds tax regime has been enacted in Italy meaning investment funds are no longer subject to tax on an accrual basis. Investors are instead taxed on a cash basis...
1 June 2012

USA: Proposed FATCA regulations

On 8 February 2012, the IRS issued proposed regulations providing rules pursuant to the Foreign Account Tax Compliance Act (FATCA). The proposed regulations are generally consistent with the guidance...
1 June 2012

UK: Worldwide Debt Cap

Worldwide debt cap rules were introduced as an extension to the UK thin capitalisation rules to ensure that UK companies bear their fair share of group debt.  It applies to accounting periods...
1 June 2012

Malta: High Net Worth Individuals Rules

The High Net Worth Individuals Rules (the Rules) have recently been introduced to attract high net worth foreign individuals to take up residence in Malta and take advantage of the beneficial rate of...
1 June 2012

China: Overseas Listed Companies ‘Share-based Incentive plans’

On 20 February 2012, the PRC State Administration of Foreign Exchange (“SAFE”) issued Circular Huifa [2012] No.7 – ‘Notice regarding certain issues related to foreign exchange administration...
1 June 2012

Resource rich Australia grapples with a two speed economy

Last month GE reported a 26% rise in revenue from Australia. The resource rich nation exceeded China revenue by US$100 million, and the company expects Australia will surpass China again in 2012...
16 May 2012

Guest post: Financial Transaction Tax: Learning crucial lessons from Sweden’s misadventure...

For many years Europe has struggled to introduce financial transaction tax (also known as FTT and Tobin tax). In 1984 when Sweden first installed FTT, it set off a chain reaction of events which...
2 May 2012

Guest post: Insights from an International Tax Advisor...

Our latest guest post is courtesy of Mario van den Broek, Partner, International Tax Services at RSM Niehe Lancée Kooij in the Netherlands. Mario is one of the most senior tax professionals in our...
18 April 2012

Australia: Removal of FBT Concessions for Foreign Executives

The Australian Government’s latest revenue raising measures are again targeting international businesses. The ‘Living away from home’ allowance and other related benefits have been denied...
1 January 2012

South Africa: Transfer Pricing – A Significant Change

With effect from 1 October 2011, South African Transfer Pricing legislation was significantly changed by the implementation of an amended Section 31 to the Income Tax Act 58 of 1962 (”the Act”)...
1 January 2012

USA: Foreign Investment in U.S. Real Estate

Is there a “best” way for a foreign individual to own U.S. real estate?  When planning to acquire U.S. real estate, foreign individuals have a number of ownership alternatives to consider each...
31 December 2011

Austria's taxation dilemma

The Financial Times published a thought-provoking article this morning that looks at a new tax introduced by the Austrian government last year. The new 25 percent levy on capital gains from stocks...
6 April 2011

International Tax Representation

Companies planning to expand their international operations need to consider a wide variety of factors: Foreign demand for the company’s products and services;  transparency and cost efficiency of...
1 April 2010

Australia: Cross-border transfer pricing reforms

On 24 May, the Government introduced into Parliament the first piece of draft legislation in its reform of Australia’s transfer pricing provisions...
12 June 2001