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.

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 would say that first of all, this year represents a ‘step up’ in the war that the Israel Tax Authority (ITA) leads to reduce the ‘black capital’ (unreported capital) phenomenon in an attempt to increase the circle of those obligated to submit financial statements.

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 expand their businesses into multiple jurisdictions as they continue to grow. However, setting up a new operation for an existing business in a foreign jurisdiction is not necessarily an easy task.

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 United States. A number of federal and state compliance and substantive tax obligations make doing business in the US potentially quite challenging, especially in California. However, many tax incentives exist that can mitigate the effect of some of these burdens.

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 United States. A number of federal and state compliance and substantive tax obligations make doing business in the US potentially quite challenging, especially in California.

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:

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 application process and conditions are comprehensively substantiated.  Types of APAs The following types of APA's are included in the instruction:

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 were a separate and independent entity, engaged in the same or similar activities, under similar circumstances.

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 automatically exchange information on their tax rulings.

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 the Controlled Foreign Companies (CFC) regime.

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