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.

Transfer Pricing News - Mexico: Pro rata cost allocation

Following a ruling of the Mexican Supreme Court of Justice on 19 March 2014, pro rata payments made outside of Mexico to non-residents are deductible – given that certain conditions are met.

Transfer Pricing News - OECD: Base Erosion and Profit Shifting

On 26 May 2014, the OECD held a webcast giving an update on the progress of the BEPS project. During this webcast the spokesmen of the OECD, Pascal Saint- Amans, declared the two-year BEPS project to be ‘on schedule’. The four discussion drafts that have been published so far contain 3,587 pages of commentary from 462 commentators spanning e.g.

Transfer Pricing News - Denmark: Transfer Pricing corrections

On 31 March 2014, the Danish tax authorities published their Transfer Pricing report for 2013. The report contains an overview of transfer pricing corrections made by the Danish tax authorities. In 2013, the Danish tax authorities adjusted the taxable income of 77 Danish companies. These corrections amounted to well over EUR 2 billion.

Transfer Pricing News - Australia: Transfer Pricing Guidance Package

On 16 April 2014, the Australian Taxation Office (ATO) published its Transfer Pricing Guidance Package. It contains two draft taxation rulings and two draft transfer pricing statements. These documents are intended to provide guidance for the application of the new transfer pricing legislation that entered into force in July 2013.

Europe: OECD BEPS

The first action of the Base Erosion and Profit Shifting (BEPS) Action Plan consists of addressing the tax challenges of the digital economy. On 24 March 2014, the OECD released a discussion draft on this subject. The discussion draft contains four main issues:

Germany: Transfer Pricing

European countries are increasingly being confronted with the problem of double taxation of profits resulting from business relations with their associated enterprises based in so-called BRICS countries (Brazil, Russia, India, China, South Africa).

Italy: Company assets revaluation

Law No. 247/2013 allows Italian companies that prepare their financial statement in accordance with the Italian Standard Accounts to revaluate the assets recorded in the financial statement as of 31 December 2012. The relevant benefits for the companies that adopt the revaluation are:

Italy: Compliance

n 1 January 2014, a new law entered into force providing additional regulations for the offsetting of tax credits relating to income taxes, withholding taxes, substitute taxes and the Regional Tax on Productive Activities (IRAP).

Chile: Tax Reform in Chile

In March 2014, the recently elected President of Chile submitted a Bill to Congress with the goal of performing several changes through a structural tax reform to generate revenues. This reform is focused on four clear objectives:

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