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: EU Savings taxation

On 10 March 2014, the European Commission issued MEMO/14/172 (Memo) to answer frequently asked questions about the EU Savings Directive and the Savings Taxation Agreements with non-Member States. In this memo, the European Commission underlines the importance of a strong unified approach in tackling tax evasion.

Brazil: Changes to Brazilian CFC rules

On 12 November 2013, the Provisional Measure (“PM”) No 627 was published and brought several changes in the Brazilian Income Tax Legislation, including provisions relating to the CFC rules.

Europe: Freedom of establishment

On 27 February 2014, the Advocate General (AG) of the European Court of Justice (ECJ) issued her opinion on the cases C-39/13, C-40/13 and C-41/13. These three cases were directed to the ECJ by the Dutch court in the light of prejudicial questions. 

Israel: Changes in Taxation of a Controlled Foreign Corporation

On 25 December 2013, the Amendment of the Income Tax Ordinance Law (the “Law”) was published. As part of the Law, significant changes were made to some of the provisions of Section 75B of the Income Tax Ordinance (the “Ordinance”), dealing with the taxation of a controlled foreign corporation (the “CFC”).

United Kingdom: Crypto Currencies (bitcoins)

Bitcoins have received their fair share of attention over the past couple of months. The volatility of the market price for bitcoins makes for a lot of potential profits. Therefore, it is not surprising that the crypto currency has been receiving more attention from the British tax authorities.

Australia: Company PE Income may not be exempt from tax

Australia’s tax law exempts from tax foreign income derived by a company “in carrying on a business, at or through a permanent establishment (“PE”)”. Capital gains are also exempt from tax where “the company used the asset wholly or mainly for the purpose of producing foreign income in carrying on a business at or through a PE”.

The Netherlands: Dividend withholding tax

The Advocate General at the Court of Justice for the European Union (CJEU) recently published his opinion on two (joined) cases about Dutch entities distributing profits to their parent companies located on Curacao in 2005 and 2006.

The Netherlands: Substance Requirements

As of 1 January 2014, financial service entities must report in their annual corporate income tax returns whether or not they meet the new substance requirements.

Belgium: Foreign Tax Credits

On 29 January 2014, the Belgian Constitutional Court ruled on the compatibility of the Belgian foreign tax credit rules with the Belgian constitution. The Constitutional Court ruled that denying the carry-forward or carry-back of an unused foreign tax credit is not unconstitutional. The same goes for not refunding an unused foreign tax credit.

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