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.

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

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.

Italian voluntary disclosure for individuals resident in Ita

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

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.

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).

Diversion of profits tax update

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

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