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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.

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 carry-forward or carry-back of an unused foreign tax credit is not unconstitutional. The same goes for not refunding an unused foreign tax credit.

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 started to use to avoid corporate taxes.

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 important measures are described below. Changes in corporate taxation

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 located on Curacao in 2005 and 2006.

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 and free trade zones of Uruguay, are exempt from income tax, when the merchandise is neither originated nor destinated to Uruguay.

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 rate on dividend distributions and companies profits. Law 26.893 provides that as from 23 September 2013:

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 in other countries in the region but there are some particular considerations to this new legislation.

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 legal provisions have been and will be enacted that will have great impact on the way we do business in Mexico. Appoint a “compliance officer”

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 targeting US taxpayers with undisclosed foreign accounts or holdings with a number of punitive rules designed to force reporting compliance.

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