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 - 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).

Peru: Double Taxation Treaties: Mexico, Korea, Portugal and Switzerland

On 27 and 28 December 2013, the Peruvian Congress approved four International Tax Treaties to avoid double taxation (Tax Treaties) signed by Peru with Mexico, Korea, Portugal and Switzerland.

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:

Venezuela: Taxation Regime on Dividends

According to the provisions in the Income Tax Law, only those dividends arising from profits generated from 1 January 2001 shall be taxed. This means that dividends arising from profits prior to 1 January 2001 shall not be taxed. The methodology used by the Law is as follows:

El Salvador: Minimum Income Tax payment of 1% declared unconstitutional

By the end of 2011, the Salvadoran Income Tax Law was modified by, amongst other things, requesting companies to pay their income tax based on the higher of (a) 30% of net profit or (b) 1% of annual taxable revenues. With the latter there is no possibility to deduct costs or expenses that were already part of the provisions in this same Law.

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