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.

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.

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.

Italian voluntary disclosure for individuals resident in Ita

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

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 Income Tax Law 1969 (CIT Act).

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:

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.

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 modified.

Diversion of profits tax update

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

Hungary: New EKAER reporting obligations

The Electronic Road Transportation Control System (EKAER) will help the tax authority in tracking every product transported in Hungary. The purpose of the system is to ensure no goods are put into circulation in Hungary that have not been previously reported to the Hungarian Tax and Customs Authority.

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