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.

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:

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. 

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”.

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.

New Zealand: Tax Risk and IRD Compliance for Multinationals

In late 2013, the IRD released their Multinational Enterprises Compliance Focus Document. This document outlines the various areas the IRD will be focusing on for the next 12 months with regards to multinational enterprises (MNEs). This article summarises the must read sections of the document.

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.

US / Canada: Investing in Canadian ULCs by US LLCs

For many years, the US-Canada Income tax treaty (the “Treaty”) did not grant treaty benefits to US Limited Liability Companies (“US LLCs”) because, in the view of the Canadian government, LLCs were not US tax residents since they are typically exempt from US tax1.

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