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.

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:

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

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.

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.

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.

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:

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).

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