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.

Thailand: Permanent establishment risk in Thailand

Permanent establishment (PE) is a common term in international tax. The concept is very common in advice concerning cross-border business expansion. Many discussions between advisers and their clients will begin with a question along the following lines: “Do these activities to be undertaken create a PE risk?”

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.

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:

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 The Corporation Tax Rate is reduced to 20% from 2015 to 2016.

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.

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:

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 highlights the risk of structuring Norwegian management of private equity funds. The case comes as a follow up of previous cases related to brokers, where internal partnership pr

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.

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