RSM Global

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.

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 as third party loans, regardless of whether or not that third party is a certified financial institution.

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 the application of the treaty and the dividend withholding tax rates. Furthermore, a limitation of benefits article has been introduced.

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 as a resident for Swedish tax purposes, provided the individual resides in Sweden permanently.

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 system) in cross- border situations to avoid double-dips.

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.

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 internationally active companies that operate in the Italian market.

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 system actively countering base erosion and profit shifting.

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 Kong and enable Hong Kong to comply with the latest international standard of tax transparency. Difference between CDTAs and TIEAs

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 losses were determined in accordance with the Finnish Business Income Tax Act. 

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