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Issue 54 – IFRS News In Brief

7 December 2015
PUBLICATIONS AND ANNOUNCEMENTS Proposed guidance on transfers of investment property open for comment until 18 March 2016 On 19 November 2015, the IASB published an exposure draft aimed at clarifying the existing guidance on transfers to, or from, investment properties in IAS 40.

Issue 53 – IFRS News In Brief

3 November 2015
PUBLICATIONS AND ANNOUNCEMENTS Proposed Interpretation for uncertainty over income tax treatments open for comment until 19 January 2016

UK - OECD delivers game changing tax measures

19 October 2015
Tax avoidance by large businesses is still a topic that attracts attention, with politicians keen to state that they will be tough on those that abuse the rules.

Issue 52 – IFRS News In Brief

16 October 2015
PUBLICATIONS AND ANNOUNCEMENTS IFRS 15 Revenue from Contracts with Customers amended for its effective date

Chile: Tax Reform Law

12 October 2015
Undoubtedly, Tax Reform Law 20.870 is the largest break in Chilean tax history. The reform has the peculiarity that its implementation will take place over four years, from 2014 up to and inlcuding 2017, in order to minimise the effects of it on the economy and companies.

Rebuilding the Global Economy

5 October 2015
Insights from an international comparative study of business ‘birth’ and ‘death’ rates.

Issue 51 – IFRS News In Brief

6 August 2015
This fifty-first edition features: Publications and Announcements

Europe: European Commission relaunches its work on a Common Consolidated Corporate Tax Base

21 July 2015
As part of its five-tier Action Plan on fair and efficient corporate taxation within the European Union (EU) the European Commission (EC) announced on 17 June 2015 that they will continue its work on the Common Consolidated Corporate Tax Base (CCCTB) by developing a completely new CCCTB proposal.

Germany: German taxation on transfer of assets to an EU-located permanent establishment compatible with the freedom of establishment

21 July 2015
In its judgement of 21 May 2015, the European Court of Justice decided that a tax legislation of a Member State which, in the case of a transfer of assets from a company located within the territory of that Member State to a permanent establishment of that company located within the territory of another Member State, provides for the disclosure of unrealised capita

Europe: European Commission presented Action Plan on corporate taxation within the EU

21 July 2015
On 17 June 2015, the European Commission (EC) presented their five-tier Action Plan on a fair and efficient corporate taxation within the EU. The Action Plan sets out a series of initiatives to tackle tax avoidance, secure sustainable revenues and strengthen the Single Market for businesses. In particular this means that:

Austria: Tax Reform Act 2015

21 July 2015
On 20 March 2015, the Ministry of Finance of Austria published the first details of the planned Tax Reform. On 16 June 2015, the Austrian Government approved a draft version of the Tax Reform Act 2015. The reform will, in principle, be applicable from 1 January 2016.  Corporate key elements of the reform are:

New Zealand Inland Revenue announce two year focus on multinationals

21 July 2015
The New Zealand Inland Revenue Department ‘IRD’ has announced a two year focus on multinational businesses. The IRD has also identified specific transactions that will be actively reviewed during this project.

Germany: German roll-over relief rules contrary to EU law

21 July 2015
In its judgement of 16 April 2015 the European Court of Justice held that the German tax legislation, which allows that capital gains realised from the sale of certain business assets (mostly land and buildings) may be ‘rolled-over’ to reinvestments into new assets if both the sold and the newly purchased assets belong to a German permanent establishment, violates

Issue 50 – IFRS News In Brief

14 July 2015
This fiftieth edition features: Publications and Announcements Proposals for amendments to pension accounting open for comment until 19 October 2015 International Accounting Standards Board - Latest Decisions Summary

UK cuts corporate tax rate again – to 18% by 2020

13 July 2015
The UK government announced yesterday that the main rate of UK corporation tax will be cut to 18% by 2020. It is currently 20% for the 2015 financial year which is the joint-lowest rate in the G20 group of countries. It will be reduced to 19% for the financial years 2017, 2018 and 2019 and then to 18% for 2020. 

OECD: OECD releases public comments received on discussion drafts on cost contribution arrangements of BEPS – Action 8

15 June 2015
On 1 June 2015, the OECD published the comments it has received on this discussion draft. In the past, the OECD had invited comments from interested parties on a discussion draft on revisions to Chapter VIII of the Transfer Pricing Guidelines on Cost Contribution Arrangements (work that relates to Action 8 of the OECD’s BEPS Action plan).

Germany/Netherlands: Treaty between Germany and Netherlands – details

15 June 2015
On 15 May 2015, the Netherlands ratified the Germany–Netherlands Income Tax Treaty 2012. This new treaty will replace the Germany–Netherlands Income and Capital Tax Treaty of 1959. The Treaty is in line with the OECD Model tax treaty. The maximum withholding tax rates included in the treaty are:

Europe: New developments on the CCCTB

15 June 2015
On 27 May 2015, the European Commission held an orientation debate on how to develop a fairer and more efficient corporate tax system. Vice-President Dombrovskis of the European Commission held a speech afterwards to point out the main topics that were discussed:

Slovakia: New Transfer Pricing documentation guidelines published

15 June 2015
On 26 May 2015, the Ministry of Finance published new guidelines on transfer pricing documentation requirements. The Guideline will apply as of 1 January 2015 and replaces the previous guidelines of October 2014.

Europe: European Commission adopts the fourth Anti Money Laundering Directive

15 June 2015
On 20 May 2015, the members of the European Parliament adopted rules to combat money laundering and terrorist financing. This is one of the key actions in the European Security Agenda that was announced last month (28 April 2015).

RSM: A network united under one name

11 June 2015
Today, we mark a watershed moment for the RSM network, as we announce the adoption of ‘RSM’ as a single global brand name. The brand name is accompanied by both a new strapline, “The power of being understood” and logo. There is no understating the importance of this decision.

Netherlands/OECD: Impact of changes of OECD Model Commentary with respect to the articles 15 and 17

4 June 2015
On 23 April 2015, clarification on the impact of the changes of the OECD Model commentary on articles 15 and 17 was published in a special Decree (effective 2 May 2015). The Decree provides guidance with respect to termination payments and on the interpretation of the term 'personal activities' of artist and sportsmen.  

Macedonia: Changes to the Corporate Income Tax law

4 June 2015
According to the last changes on the Corporate Income Tax law (Official Gazette of the Republic of Macedonia no. 112/14 from 25/07/2014), the obligation for paying corporate income tax (CIT) on net income is restored as from the fiscal year 2014. The CIT rate remains 10%.

Europe OECD: The OECD published the revised discussion draft on Action 7

4 June 2015
On 15 May 2015, the OECD released a revised discussion draft on Action 7. The revision is a follow-up to the discussion draft on Action 7 of 31 October 2014, which addressed a number of PE avoidance strategies and potential strategies to deal with these.

Poland: Proposed legislation on Country by Country reporting

4 June 2015
Poland proposed legislation on Country by Country (CbC) reporting and related transfer pricing reporting obligations. The proposed legislation reflects the reporting obligations as included in Action 13 of the OECD’s initiative on Base Erosion and Profit Shifting. To be more specific, Poland has introduced thresholds for the Local File, Master File and CbC-report.

Europe: European Commission publishes strategy on the Digital Single Market

4 June 2015
The European Commission (EC) published its strategy on the Digital Single Market on 6 May 2015. The strategy includes 16 initiatives to be delivered by the end of 2016 and is built on three pillars: Access, Environment and Economy & Society.

Issue 49 – IFRS News In Brief

3 June 2015
This forty-ninth edition features: Publications and Announcements

South Africa: The true cost to an employer of an expatriate in South Africa

20 May 2015
With technology making the world a smaller place, it is understandable that large corporations expand their businesses into multiple jurisdictions as they continue to grow. However, setting up a new operation for an existing business in a foreign jurisdiction is not necessarily an easy task.

China: New Tax Reporting Obligations on Indirect Transfer of PRC Taxable Investments

20 May 2015
Non-US businesses face a variety of complex tax burdens when they choose to do business in the United States. A number of federal and state compliance and substantive tax obligations make doing business in the US potentially quite challenging, especially in California.

USA: Businesses entering and investing into the United States through California — 2015

20 May 2015
Non-US businesses face a variety of complex tax burdens when they choose to do business in the United States. A number of federal and state compliance and substantive tax obligations make doing business in the US potentially quite challenging, especially in California. However, many tax incentives exist that can mitigate the effect of some of these burdens.

Israel: Voluntary disclosure programme tackles the problem of unreported capital

20 May 2015
If I had to summarise 2014 in one sentence, based on the economic and law-enforcement aspects, I would say that first of all, this year represents a ‘step up’ in the war that the Israel Tax Authority (ITA) leads to reduce the ‘black capital’ (unreported capital) phenomenon in an attempt to increase the circle of those obligated to submit financial statements.

Thailand: Permanent establishment risk in Thailand

20 May 2015
Permanent establishment (PE) is a common term in international tax. The concept is very common in advice concerning cross-border business expansion. Many discussions between advisers and their clients will begin with a question along the following lines: “Do these activities to be undertaken create a PE risk?”

Venezuela: Transfer Pricing

13 May 2015
From 1 January 2001, Venezuela changed its territorial income tax system to include non territorial income tax; in other words, a Worldwide Tax System.

Denmark: Record breaking Transfer Pricing adjustment in Denmark

13 May 2015
The Danish tax authorities have, for the third year in a row, increased the taxable income of multinational groups with a record-breaking amount. The latest years’ audit results in 20 billion DKK: The Danish tax authorities have, for the third year in a row, increased the taxable income of multinational groups with a record-breaking amount.

Germany: Qualification conflicts and Treaty overriding

13 May 2015
German domestic law requalifies rental and interest income into business income in cases where a business consists of two entities under common control or when the shareholder holds assets that are key for the business, privately.

France: Updated list of tax-abusive structures and schemes

13 May 2015
On 1 April 2015, the French tax authorities announced several measures aimed at improving legal certainty for individuals and businesses. To be more specific, the tax authorities published a list of practices and transactions that are deemed to be abusive:  

Czech Republic: New VAT rate as from 2015

13 May 2015
The Czech Ministry of Finance has announced a new second reduced VAT rate of 10%, applicable as of 1 January 2015 in the Czech Republic. As a result, the following three VAT rates are currently applicable in the Czech Republic:

Russia: Review of the Russian Federal Legislation in the period 1 January 2015 up to and including 31 March 2015

13 May 2015
Changes in the procedure for calculating interest on borrowed fund 

Uruguay: Uruguay meets international standards of fiscal transparency

8 May 2015
In March 2015, the Ministry of Finance reported that the Global Forum on Transparency and Exchange of Information for Tax Purposes, the multilateral organisation in which international standards on transparency and tax cooperation are developed, approved unanimously the technical report referred to the Uruguayan case corresponding to Phase 2.  

Issue 48 - IFRS News In Brief

8 May 2015
This forty-eighth edition features: International Accounting Standards Board - Latest Decisions Summary Effective date of IFRS 15 Revenue from Contracts with Customers (narrow-scope exposure draft)

Brazil: PIS/COFINS-Importation and PIS/COFINS on Financial Revenues

8 May 2015
In connection with a recent statement to increase revenue collection, the Brazilian Government published new rules related to PIS/COFINS. The main points are:

United Kingdom: Budget for 2015/2016 – Business taxation

15 April 2015
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.

Albania: Ministry of Finance published instruction on Advance Pricing Agreements

15 April 2015
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

15 April 2015
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

15 April 2015
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.

Germany: New ordinance on the 'attribution of income to permanent establishments' published

15 April 2015
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.

Issue 47 – IFRS News In Brief

10 April 2015
This forty-seventh edition features: IFRS Interpretations Committee - Latest Decisions Summary Foreign currency transactions and advance consideration draft interpretation of IAS 21 International Accounting Standards Board - Latest Decisions Summary

France: French 2015 Finance Bill and 2014 amended Finance Bill: Group Regime

18 March 2015
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

18 March 2015
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).

Greece: Intragroup dividends withholding tax exemption

18 March 2015
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)

18 March 2015
In July 2014, Cyprus harmonised its legislation in an effort to modernise its legislation on investment fund products in accordance with the EU directives.

Belgium: Introduction of the liquidation reserve

18 March 2015
On 1 October 2014, the former Belgian government increased the withholding tax on liquidation proceeds from 10% to 25%. Under certain conditions companies were allowed to benefit from a transitional regime resulting in a 10% withholding tax rate.

Issue 46 – IFRS News In Brief

6 March 2015
This forty-sixth edition features: IFRS Interpretations Committee- Latest Decisions Summary Accounting for income tax assets and liabilities when there are tax uncertainties The forthcoming draft interpretation of IAS 21 International Accounting Standards Board - Latest Decisions Summary

Issue 45 - IFRS News In Brief

5 February 2015
This forty-fifth edition features: International Accounting Standards Board - Latest Decisions Summary Leases (IFRS due H2/2015) Insurance Contracts (redeliberations on the 2013 ED) Conceptual Framework (exposure draft due Q1/2015)

Issue 22 - RSM Reporting

13 January 2015
This twenty-second edition features:

Issue 44 - IFRS News In Brief

6 January 2015
This forty-fourth edition features: Publications and Announcements IFRS 10, IFRS 12 and IAS 28 amended for investment entity requirements IAS 1 amended under the Disclosure Initiative project  Proposals for amendments to IAS 7 open for comment until 17 April 2015 

Mexico: Deduction for expenses apportioned from non-Mexican companies

19 December 2014
On 10 October 2014, Mexico’s federal tax authority, the Servicio de Administracion Tributaria (SAT), published a package of miscellaneous tax rules (the “October 10 Rules”) that included guidance on various Mexican tax provisions.

Hong Kong: Recent developments: Exchange of Information

19 December 2014
In 2014, Hong Kong signed seven Tax Information Exchange Agreements (TIEAs) with the US and six Nordic jurisdictions. The signing of the TIEAs marks a new era of Exchange of Information (EOI) in Hong Kong.

Hungary: New EKAER reporting obligations

19 December 2014
The Electronic Road Transportation Control System (EKAER) will help the tax authority in tracking every product transported in Hungary. The purpose of the system is to ensure no goods are put into circulation in Hungary that have not been previously reported to the Hungarian Tax and Customs Authority.

RSM tax leaders expect minimal change to corporate tax rates across the world, despite G20 and OECD reform movement

12 December 2014
The global tax system was built for an industrial age dominated by western powers but it is no longer fit for an economy driven increasingly by the internet, which is changing commerce, public service and lives across the world in ways never imagined even a decade ago.

Minimal change to corporate tax rates expected in spite of global tax infrastructure reform

8 December 2014
The majority of tax advisers expect corporate tax rates to remain relatively unchanged over the next three years, according to research by RSM, the seventh largest global network of independent audit, tax and advisory firms. This is in spite of global tax reform led by the OECD aimed at targeting tax avoidance by multinational corporations. 

Issue 43 - IFRS News In Brief

4 December 2014
This forty-third edition features: Publications and Announcements Proposals for amendments to IFRS 2 open for comment until 25 March 2015  IFRS Interpretations Committee - Latest Decisions Summary

Chile: Chilean Tax Reform

10 November 2014
This change in taxation for companies has generated a significant slowdown in economic growth (current 5% down to 2% in the future). The gradual change in company income tax (20% in 2013) will be as follows:

Nicaragua: Self-transfer of Value Added Tax (VAT)

10 November 2014
The figure of the self-transfer of the Value Added Tax (VAT) applies when general services are provided or when the enjoyment or benefit is obtained from the use of goods by natural resident persons, or natural or legal non-resident, not responsible tax collectors of VAT or not registered before the tax authority.

Venezuela: Exchange Trilogy in force in Venezuela

10 November 2014
The exchange rate established by 'CENCOEX' is fixed and is set at 6,30 bolívares (Bs.) per U.S. dollar. It is applicable to items such as medicines, food, housing, education and any other item designated by the institution. So far, several items directly associated to the needs of the government sector have been added.  

Our future starts today

5 November 2014
The theme of the recent RSM World Conference in Barcelona was “Our Future Starts Today” – it was  a celebration of the foundations laid during the last 50 years and an exploration of building upon these foundations for our future.

RSM celebrates 50 years of growth at annual World Conference

5 November 2014
RSM International, the seventh largest global network of independent audit, tax and advisory firms, held its annual RSM World Conference in Barcelona from 27-31 October 2014.

Transatlantic Trade and Investment Partnership

1 November 2014
In February 2013, the European Union (EU) and the United States (U.S.) commenced negotiations for a Transatlantic Trade and Investment Partnership (TTIP). The proposed pact would create the world’s biggest free trade area.

Uruguay: Financial Inclusion Law

26 October 2014
On 29 April 2014, Law No. 19,210 (or Financial Inclusion Law) was approved. The Law aims to promote access to banking services and the use of electronic means of payment, such as debit card, credit card and electronic transfers, by all the population.

Oman: seeing with 20/20 vision

24 October 2014
A guest blog by George Mathew, Managing Partner at George Mathew & Co, member firm of RSM International

Issue 21 - RSM Reporting

20 October 2014
This twenty-first edition features:

Cyber Crime: A Growing Threat to Global Companies

1 October 2014
Cyber security, once limited to the expertise of Information Technology specialists, has become a business-critical issue engaging senior corporate leaders worldwide.

European giants, entrepreneurs and start-ups all make the National Champions list

10 September 2014
Guest post from Robert Coles, RSM Europe Regional Leader

Hungary: Advertisement Tax

1 September 2014
Act XXII of 2014 on Advertisement Tax enters into force on 15 August 2014. The new public burden does not only concern the publishers of press products and commercial television channels.

Hong Kong: Effects of the international tax framework

1 September 2014
The globalisation and development of the digital economy has fostered continuous growth of cross-border transactions. As different countries adopt different tax regimes, taxpayers may avoid taxation in their home countries by pushing activities abroad to low or no tax jurisdictions.

China: Corporate Income Tax Incentives

1 September 2014
In order to encourage investment in certain areas in the People’s Republic of China, the Ministry of Finance (MOF) and the State Administration of Taxation (SAT) jointly published the notice Caishui 2014 No.

USA: New global tax and information reporting regimes create risks and burdens for businesses

1 September 2014
Emboldened by the plethora of new legislation and guidance passed by the United States, many countries are considering implementing a standardised global information reporting (GIR) system.

Europe: The Mini One Stop Shop for e-services, broadcasting and telecom services

1 September 2014
In January 2015 the VAT legislation providing for the place of taxation for e-services, broadcasting and telecom services will change. Although the actual change in legislation will be minimal, it will have a substantial impact on the providers of these services from a VAT compliance perspective.

Argentina: Unconstitutionality of the Minimum Presumptive Income Tax. New pronouncement of the Supreme Court of Justice

26 August 2014
The Supreme Court ruled, once again, that the Minimum Presumptive Income Tax in the Diario Perfil SA c/AFIP-DGI case is unconstitutional, in line with the June 2010 ruling in the Hermitage SA case.

Panama: Still on grey listing

26 August 2014
At the end of 2009, the Panamanian government adopted a national policy with the purpose of being excluded from the OECD grey listing.

Issue 40 - IFRS News In Brief

30 July 2014
This fourtieth edition features: Publications and Announcements Release of the final comprehensive standard on financial instruments IFRS Interpretations Committee - Latest Decisions Summary

Issue 20 - RSM Reporting

17 July 2014
This twentieth edition features: Our experts in UAE Baasab B. Deyb discusses insurance law - the journey so far and the way forward Martyn Jones, President of the ICAEW Discusses how to restore trust in the accounting and auditing profession globally

Issue 39 - IFRS News In Brief

30 June 2014
This thirty-nineth edition features: Publications and Announcements IAS 16 and IAS 41 amended for bearer plants Proposals for amendments to IFRS 10 and IAS 28 open for comment until 15 September 2014 International Accounting Standards Board - Latest Decisions Summary

Indonesia: the wind blows hot and cold

24 June 2014
When Jim O’Neill coined the term ‘MINT’ for the economies of Mexico, Indonesia, Nigeria and Turkey, he stated that Indonesia, due to be ranked as the seventh largest GDP globally by 2050, had the potential to be “more compelling than Russia”, principally because of its growing population of young workers.

Transfer Pricing News - OECD: Base Erosion and Profit Shifting

23 June 2014
On 26 May 2014, the OECD held a webcast giving an update on the progress of the BEPS project. During this webcast the spokesmen of the OECD, Pascal Saint- Amans, declared the two-year BEPS project to be ‘on schedule’. The four discussion drafts that have been published so far contain 3,587 pages of commentary from 462 commentators spanning e.g.

Transfer Pricing News - Denmark: Transfer Pricing corrections

23 June 2014
On 31 March 2014, the Danish tax authorities published their Transfer Pricing report for 2013. The report contains an overview of transfer pricing corrections made by the Danish tax authorities. In 2013, the Danish tax authorities adjusted the taxable income of 77 Danish companies. These corrections amounted to well over EUR 2 billion.

Transfer Pricing News - Australia: Transfer Pricing Guidance Package

23 June 2014
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.

Transfer Pricing News - Mexico: Pro rata cost allocation

23 June 2014
Following a ruling of the Mexican Supreme Court of Justice on 19 March 2014, pro rata payments made outside of Mexico to non-residents are deductible – given that certain conditions are met.

Business Births and Deaths

17 June 2014
I am delighted that RSM’s second annual report - The Road to Recovery: Insights from an international comparative study of business birth and death rates – has been published and is now available on our website. The report analyses national statistics on active businesses across 38 countries globally.

Italy: Company assets revaluation

17 June 2014
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:

Europe: OECD BEPS

17 June 2014
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

17 June 2014
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).

G7 closing gap with BRICS in creation of new businesses

16 June 2014
The gap in growth rates of new business formation between the G7* and BRICS** economies narrowed in the year to 2013***, according to research of the most recent globally comparable data by RSM, the seventh largest global network of independent audit, tax and advisory firms.  RSM reviewed 36 countries in its report, ‘Rebuilding the Global Economy’.

Italy: Compliance

12 June 2014
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).

Issue 38 - IFRS News In Brief

31 May 2014
This thirty-eighth edition features: Publications and Announcements

13 Best Businesses In Europe Announced by RSM and EBA

29 May 2014
The 13 winners of the 2013/4 European Business Awards sponsored by RSM International were announced last night at an exclusive awards ceremony held in Athens and attended by businesses leaders, politicians and academics from across Europe.

Technology Sector Cleans Up With Six Wins At European Business Awards

28 May 2014
The technology sector across Europe is celebrating following it’s clean up at last night’s European Business Awards final in Athens, sponsored by RSM International. Competing with over 100 businesses from across Europe, six companies won separate awards out of the strong technology shortlist, which had 18 businesses making it to the final.

Europe’s Software Development Sector Celebrates Four Wins At European Business Awards Final

28 May 2014
The software development sector has dominated this year’s, European Business Awards, sponsored by RSM International, winning four out of the 13 awards.

Pharmaceuticals Industry Scoops Two European Business Awards

28 May 2014
The pharmaceuticals sector celebrated a double-win last night at the seventh European Business Awards gala ceremony in Athens, sponsored by RSM International. Competing with over 100 businesses from across Europe, the two companies from Portugal and Spain beat stiff competition to be crowned European Business Awards winners.

Airspeed Telecom Founder Wins Prestigious RSM Entrepreneur Of The Year Award

28 May 2014
Liam O’Kelly, Founder and CEO of AirSpeed Telecom, was announced winner of the RSM Entrepreneur of the Year Award at the prestigious European Business Awards ceremony last night in Athens. RSM International, the sponsor of the Entrepreneur of the Year award category, is the seventh largest worldwide network of independent audit, tax and advisory firms. 

Manufacturing Sector Celebrates Triple Win At European Business Awards

28 May 2014
The manufacturing sector is celebrating a triple win following last night’s European Business Awards final in Athens, sponsored by RSM International. Competing with over 100 businesses from across Europe, the three companies were part of a strong manufacturing shortlist of 23 businesses making it to the final.

RSM International celebrates 50th anniversary across the globe

20 May 2014
RSM International, the seventh largest global network of independent audit, tax and advisory firms, is proud to celebrate its 50th anniversary in 2014.

Issue 19 - RSM Reporting

15 May 2014
This nineteenth edition features:

Chile: Tax Reform in Chile

8 May 2014
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

8 May 2014
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

8 May 2014
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.

Nicaragua: New Tax Law in Nicaragua

8 May 2014
On 1 January 2013, the Government of Nicaragua passed Law Nº 822: 'CONCERTATION TAX LAW'(CTL). This Act and its regulations contain important changes in the tax regime.

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

8 May 2014
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.

Issue 37 - IFRS News In Brief

30 April 2014
This thirty-seventh edition features: Publications and Announcements Discussion paper on accounting for macro hedging open for comment until 17 October 2014 International Accounting Standards Board - Latest Decisions Summary

Baker Tilly in the UK to Join RSM International Network

15 April 2014
RSM International, the worldwide audit, tax and advisory network of independent firms, has enhanced its international representation by admitting Baker Tilly as its UK member firm. This admission reinforces RSM’s position as the 7th largest global accounting network. 

Germany: Treaty override provision

1 April 2014
On 11 December 2013, the German Federal Tax Court (FTC) submitted the question to the Federal Constitutional Court (FCC) whether the treaty override provision (article 50d (10) of the Personal Income Tax Act) is unconstitutional.

Europe: How European VAT impacts US companies

1 April 2014
When US companies deal with value added tax “VAT” challenges in Europe, whether newly established or well established, they often fall into the same avoidable traps.

Europe: Freedom of establishment

1 April 2014
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

1 April 2014
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

1 April 2014
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

1 April 2014
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)

1 April 2014
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

1 April 2014
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.

Belgium: VAT

1 April 2014
On 3 March 2014, the Belgian Council of Ministers issued a press release concerning the new turnover threshold under which small businesses and associations qualify for VAT exemption. The turnover threshold will be increased from EUR 5,580 (current) to EUR 15,000 (announced).

Israel: Changes in Taxation of a Controlled Foreign Corporation

1 April 2014
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”).

Issue 36 - IFRS News In Brief

31 March 2014
This thirty-sixth edition features: Publications and Announcements Proposals for narrow-focus clarifying amendments to IAS 1 open for comment until 23 July 2014 IFRS Interpretations Committee - Latest Decisions Summary

An Introduction to Islamic Finance

1 March 2014
Islamic finance is an emergent series of financial products that have been developed to meet the requirements and constraints of people that would like to follow the Shari’ah law. Islamic finance is a term that reflects financial business that is not contradictory to the principles of Shari’ah.

The Netherlands: Substance Requirements

1 March 2014
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

1 March 2014
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.

Europe: Parent Subsidiary Directive

1 March 2014
On 25 November 2013, the European Commission (EC) proposed to change the European Parent Subsidiary Directive (PSD). The EC wishes to close certain loopholes in the PSD that multinationals may have started to use to avoid corporate taxes.

France: French Finance Bills

1 March 2014
The French parliament has approved the amended Finance Bill 2013 and the new Finance Bill 2014. The bills include changes to corporate taxation, individual taxation and indirect taxes. Some of these important measures are described below. Changes in corporate taxation

The Netherlands: Dividend withholding tax

1 March 2014
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.

Costa Rica: New Transfer Pricing legislation

28 February 2014
On 13 September 2013, the Ministry of Finance published Decree 37898-Hthat establishes new legislation on transfer pricing for Costa Rican taxpayers. Much of the legislation is common to that used in other countries in the region but there are some particular considerations to this new legislation.

Uruguay: Income Tax Exemption for marketing merchandise of foreign origin

28 February 2014
According to legislation in force in Uruguay, activities by foreign entities outside Uruguay; and those with goods in transit or deposited in customs facilities, port facilities, bonded warehouses and free trade zones of Uruguay, are exempt from income tax, when the merchandise is neither originated nor destinated to Uruguay.

USA: Cross Border Tax Enforcement and FATCA

28 February 2014
The U.S. government continues to view offshore tax evasion as a significant loss of potential tax revenue. As a result, the government has been increasing its international enforcement efforts and targeting US taxpayers with undisclosed foreign accounts or holdings with a number of punitive rules designed to force reporting compliance.

Issue 35 - IFRS News In Brief

28 February 2014
This thirty-fifth edition features: IFRS Interpretations Committee - Latest Decisions Summary International Accounting Standards Board - Latest Decisions Summary

Argentina: Taxation of gains from the transfer of shares and dividends

28 February 2014
Significant amendments have been introduced to Income Tax regulations, extending the tax scope to include certain financial gains, that were exempt from income tax and establishing an additional tax rate on dividend distributions and companies profits. Law 26.893 provides that as from 23 September 2013:

Finland: Dividend withholding tax

1 February 2014
On 25 September 2013, the Finnish Supreme Administrative Court (SAC) ruled that interest must be paid when refunding Dividend Withholding Tax (DWT) that has been levied incorrectly from dividends intended for foreign entities. This was already the case for DWT levied from dividends intended for Finnish entities.

Italy: Advance tax rulings & permanent establishments

1 February 2014
On 23 December 2013, the Italian government published a decree concerning the Italian advance tax ruling procedures.

Greece: Thin capitalisation rules

1 February 2014
On 31 December 2013, the Greek parliament approved an amendment to the thin capitalisation rules. Greek thin capitalisation rules apply to all types of loans. This includes intragroup loans as well as third party loans, regardless of whether or not that third party is a certified financial institution.

United Kingdom: Tax Treaties

1 February 2014
On 27 December 2013 the protocol to the UK–India tax treaty entered into force. As a result of this protocol, several provisions of the treaty are altered, e.g. the recognition of partnerships for the application of the treaty and the dividend withholding tax rates. Furthermore, a limitation of benefits article has been introduced.

Sweden: Personal Income Tax

1 February 2014
An individual is considered to be a resident for Swedish tax purposes if the individual has a home at his disposal in Sweden. Any individual without such a real home within Sweden can also be treated as a resident for Swedish tax purposes, provided the individual resides in Sweden permanently.

Issue 34 - IFRS News In Brief

31 January 2014
This thirty-fourth edition features: Publications & Announcements Interim guidance issued on rate-regulated activities Post-implementation review of IFRS 3 open for comment until 30 May 2014 International Accounting Standards Boards - Latest Decisions Summary

Luxembourg: Upcoming tax policy

22 January 2014
In December 2013, the new Luxembourg government announced its political program for the upcoming years. The announcement contains several direct and indirect tax measures.

Italy: 2014 Budget

22 January 2014
On 27 December 2013, the Italian 2014 Budget was approved by the Italian parliament as well as published in the official gazette. The 2014 Budget contains several changes, some of which may affect internationally active companies that operate in the Italian market.

Germany: Corporate income tax

22 January 2014
In 2013 the German legislator renewed section 14, par. 1, no 5 of the German Corporate Tax Act (GCTA). The new rule limits the utilisation of tax losses in fiscal unities (the German group taxation system) in cross- border situations to avoid double-dips.

Finland: Cross-border mergers

1 January 2014
The Finnish Supreme Administrative Court applied to the Court of Justice for the European Union’s Marks & Spencer doctrine to a cross-border merger involving tax deductible losses. The final losses were determined in accordance with the Finnish Business Income Tax Act. 

USA: Interest-Charge Domestic International Sales Corporations

1 January 2014
An interest-charge domestic international sales corporation (IC-DISC) can be a powerful tax savings opportunity for many companies exporting products. An IC-DISC is a domestic corporation that primarily engages in foreign sales and exporting activity. Many years ago, the U.S. government created this law as a means to promote U.S.

Issue 18 - RSM Reporting

1 January 2014
This eighteenth edition features:

Germany: Depreciation of real estate

1 January 2014
Before 2009, non-resident companies directly holding German real estate were denied the higher depreciation rate of 3%. The Lower Fiscal Court of Cologne ruled that forcing non-resident companies directly holding German real estate to use the regular 2% depreciation rate is a breach of the free movement of capital.

United Kingdom: Upcoming tax policy

1 January 2014
On 5 December 2013, the British government published upcoming changes to the UK tax regime. These upcoming changes will be of particular importance to the employers of expats, as they will target dual contract arrangements and offshore intermediary employment structures. United Kingdom: Upcoming tax policy

Republic of Ireland: An Update

1 January 2014
1. General economic update

Italy: Compliance

1 January 2014
Under Italian tax law, companies are obligated to provide the Italian tax authorities with a list of the assets the company provided for use by its private individual shareholders, as well as loans and capital the company has received from its private individual shareholders. Failure to comply results in penalties.

Hungary: Final tax package 2014

1 January 2014
As it was apparent from the proposal put forward in October that the volume of changes brought by the tax package of 2014 is altogether less significant than that of similar packages of the previous years.

Italy: New financial instruments

1 January 2014
provide a periodic analysis at least every six months of the value of the issued financial instruments. 4. The last financial statements of the company must be certified by an auditing firm. 5. The financial instruments may only be sold to qualified investors (as defined in DLgs no. 58/1998).

Europe: Changes to Parent Subsidiary Directive

1 January 2014
On 25 November 2013, the European Commission proposed to amend the European Parent Subsidiary Directive (PSD). Corporate tax avoidance has been at the top of the political agenda of EU and non-EU countries alike for over a year. Likewise, the G20 as well as the G8 have emphasized the urgency of countering corporate tax avoidance.

Australia: Domestic ship and aircraft tax

1 January 2014
Australia’s domestic tax law imposes a 5% tax on amounts paid to foreign owners or charterers of ships or aircraft for the carriage of passengers, live-stock, mail or goods shipped in Australia (section 129 of the Income Tax Assessment Act, 1936). Section 129 can apply irrespective of where the passengers or goods are discharged.

Germany: Updated tax policy

1 January 2014
On 27 November 2013, the German government published its tax policy for the upcoming four years. While not containing concrete, imminent measures the policy is a valuable insight into Germany's tax system actively countering base erosion and profit shifting.

Hong Kong: Inland Revenue Amendment Bill – Exchange of Information (EOI)

1 January 2014
The Inland Revenue (Amendment) Bill (the Bill) was passed by the Legislative Council on 10 July 2013. It provides the legal framework to liberalise the Exchange of Information (EOI) regime in Hong Kong and enable Hong Kong to comply with the latest international standard of tax transparency. Difference between CDTAs and TIEAs

Issue 33 - IFRS News In Brief

31 December 2013
This thirty-third edition features: Publications & Announcements

Spain: 2014 Budget

28 December 2013
On 26 December 2013, the Budget for Spain’s fiscal year 2014 was published in the official gazette. It contains several new tax measures as well as the extension of existing measures that are to increase Spanish tax revenues.  

Issue 32 - IFRS News In Brief

30 November 2013
This thirty-second edition features: Publications & Announcements

Cross-Border Flows and Client Services

1 November 2013
This article examines the impact of cross-border flows on client demand for accounting, tax and consulting services. The findings of this study were presented at the RSM World Conference in Amsterdam in October 2013. Measuring Cross-Border Flows

RSM International partners with BP to make RSM World Conference carbon neutral

24 October 2013
RSM International, the seventh largest global network of independent audit, tax and advisory firms, has partnered with BP to ensure its annual World Conference on the 27–30 October in Amsterdam is carbon neutral.

RSM International launches new RSM ITAX Academy

11 October 2013
RSM International, the seventh largest network of independent audit, tax and advisory firms, is celebrating the successful launch of its RSM ITAX Academy, a two year programme for the network’s future leaders in international tax.

RSM network celebrates its global connections on the world stage

16 September 2013
RSM, the seventh largest network of independent audit, tax and advisory firms, celebrated its second RSM World Day on Thursday 12 September, following on from the award-wining success of last year’s inaugural event. 

RSM International’s Bob Dohrer re-elected as Chairman of Forum of Firms

6 September 2013
RSM International, the seventh largest global network of independent audit, tax and advisory firms, is pleased to announce that Bob Dohrer, the network’s Global Leader for Quality and Risk, has been re-elected for a second 3-year term as Chairman of the Forum of Firms (FoF).

RSM continues to strengthen African representation by admitting the 5th largest firm in Nigeria

4 September 2013
RSM, the seventh largest global network of independent audit, tax and advisory firms, has further strengthened its presence in Africa with the admittance of SIAO Partners, Nigeria’s fifth largest accounting firm by revenue, to the network.

Issue 17 - RSM Reporting

1 September 2013
This seventeenth edition features:

RSM International evaluates options in the context of announcement of sale of RSM Tenon (UK) to Baker Tilly

22 August 2013
The Board of RSM International, the world’s seventh largest audit, tax and advisory network, is reviewing its options with regard to its UK membership following the announcement of the combination of RSM Tenon with Baker Tilly.

Germany: Tax Law Update

1 August 2013
On 29 June 2013, numerous changes to the German tax law were published in the Federal Law Gazette and are applicable as of that date unless indicated otherwise. The changes in the law mainly concern the areas below. Correspondent taxation extended to dividends

Hong Kong: Beneficial Ownership

1 August 2013
This article aims to provide you with the salient points of Circular 165. 1. Circular 601

Australia: Investment Manager Regime

1 August 2013
On 4 April 2013, the Government released exposure draft legislation and explanatory materials which propose to implement the third and final element of the Investment Manager Regime (IMR) as announced by the Government on 16 December 2011. Context of amendments

Uruguay: Benefits of Uruguayan Trusts

1 August 2013
Trusts in Uruguay are ruled under Law 17,703 which was published on 4 November 2003.

United Kingdom: Information Exchange Agreements

1 August 2013
Whilst governmental attacks on tax avoidance seem to be rarely out of the financial news, the UK Government is also tackling tax evasion by entering into information exchange agreements with a number of tax havens, many of which are British Crown Dependencies.

Peru: Tax Benefit with 'technical assistance'

1 August 2013
According to the general rule in Peruvian Income Tax (IT) Law, services rendered by non-resident individuals are subject to a 30% withholding income tax (WHT) rate. However, services that qualify as ‘technical assistance’ are levied with a 15% WHT rate applied on the Peruvian source income.

USA: Withholding under US FATCA rules delayed

1 August 2013
On 12 July 2013, the IRS issued Notice 2013-43 (the notice) that extends the date on which Foreign Account Tax Compliance Act (FATCA) withholding is to begin to 1 July 2014.

Mexico: Changes in Mexico's Federal Labour Law

1 August 2013
On 1 December 2012, important changes in Mexico’s Federal Labour Law (the 2012 amendments) came into effect.

Issue 29 - IFRS News In Brief

31 July 2013
This twenty-ninth edition features: Publications & Announcements Discussion paper for a new conceptual framework open for comment until 14 January 2014 IFRS Interpretations Committee - Latest Decisions Summary

Rate of new business creation among BRICS economies seven times faster than G7 since the financial crisis

25 July 2013
The net rate of business creation among BRICS1 economies has been over seven times faster than the G7 since the financial crisis, according to research by RSM, the seventh largest global network of independent audit, tax and consulting firms.

RSM Torrent merges with Razzetto to create leading Latin American firm

4 July 2013
RSM, the seventh largest global network of independent audit, tax and advisory firms, has further strengthened its presence in Argentina and the wider Latin American region following the merger of RSM Torrent with Razzetto Lopez Rodriguez & Cordoba (Razzetto) a highly-regarded top ten Argentine firm. The enlarged firm will be known as RSM Torrent Razzetto.

Issue 28 - IFRS News In Brief

30 June 2013
This twenty-eighth edition features: Publications & Announcements

RSM sponsors IFRS Foundation conference

27 June 2013
RSM, the seventh largest global network of independent audit, tax and advisory firms, are sponsors of the IFRS Foundation Conference in Amsterdam from 27-28 June 2013.

Comments from RSM on the G8 Summit discussions on ensuring tax compliance

18 June 2013
Quotes attributable to Mario van den Broek and Aad Rozendal from RSM, the seventh largest worldwide network of independent audit, tax and advisory firms. According to the IAB World Survey, RSM is the 5th largest global network for providing tax services. Mario van den Broek, Partner, International Tax Services, RSM Netherlands, comments:

Turk Ekonomi Bankasi wins European Business Award for Customer Focus

12 June 2013
Turk Ekonomi Bankasi (TEB) was announced winner of the award for Customer Focus at the prestigious European Business Awards ceremony held in Istanbul. RSM, sponsor of the Awards, is the seventh largest worldwide network of independent audit, tax and advisory firms.

Cambridge Satchel Company founder wins RSM Entrepreneur of the Year award

7 June 2013
Julie Deane, founder and CEO of The Cambridge Satchel Company awarded coveted prize at the European Business Awards 

Issue 16 - RSM Reporting

1 June 2013
This sixteenth edition features:

Issue 27 - IFRS News In Brief

31 May 2013
This twenty-seventh edition features: Publications & Announcements

RSM strengthens presence in Central America with admission of Honduran firm

28 May 2013
RSM, the seventh largest global network of independent audit, tax and advisory firms, has further strengthened its presence in Latin and Central America through the admission of a member firm in Honduras. 

RSM Sponsors INSOL International Conference

21 May 2013
RSM, the seventh largest global network of independent audit, tax and advisory firms, are sponsors of the INSOL International Conference, taking place in The Hague. Over 800 insolvency professionals from across accountancy, banking, insurance and law will be attending the congress taking place on 19-22 May 2013. 

Issue 26 - IFRS News In Brief

30 April 2013
This twenty-sixth edition features: Publications & Announcements

RSM extends client services to Bangladesh and Palestine

16 April 2013
RSM, the seventh largest global network of independent audit, tax and advisory firms, has expanded its geographical reach and client service capabilities in both Bangladesh and Palestine.  

RSM appoints Mike Kirley as Chairman of the Board of Directors

9 April 2013
RSM, the seventh largest global network of independent audit, tax and advisory firms, has appointed Mike Kirley as Chairman of its international board of directors.

The Future of Renewable Energy

4 April 2013
The global development of renewable energy encounters a number of obstacles:

Issue 25 - IFRS News In Brief

21 March 2013
This twenty-fifth edition features: Publications & Announcements

Productivity Growth in the Developed Economies

1 March 2013
RSM International’s “Prospects for the World Economy” (Talking Points, January 2013) offers a sober forecast for GDP growth in the advanced industrialized countries.

Netherlands: Five questions about aggressive tax planning

1 March 2013
In recent months, there have been several reports by journalists into the tax affairs of multinational corporations resulting in public anger and accusations of tax avoidance.

Australia: Transfer Pricing: Tax Laws Amendment Bill

1 March 2013
Further to the release of the Treasury’s exposure draft in mid-November, the Government has now introduced into Parliament stage two of the transfer pricing reforms, the Tax Laws Amendment (Countering Tax Avoidance and Multinational Profit Shifting) Bill 2013.

United Kingdom: New Controlled Foreign Company rules

1 March 2013
The UK’s new Controlled Foreign Company (CFC) legislation is effective for all accounting periods beginning on or after 1 January 2013. This represents a timely wholesale revision of the rules as over the last few years there has been numerous revision to the rules in reaction to various recent Court of Justice of the European Union cases.

Hungary: Allowances for special enterprise zones

1 March 2013
From 1 January 2013, the scope of tax allowances available to companies operating in special or free enterprise zones was extended in a number of tax types.

Issue 15 - RSM Reporting

1 March 2013
This fifteenth edition features:

USA: New regulations modify rules governing outbound transfers

1 March 2013
On 18 March 2013, the IRS and Treasury published final, temporary and proposed regulations under Sections 367 and 12481 that address the treatment of outbound transfers of property by US corporations and other matters (“2013 Regulations”).

Issue 24 - IFRS News In Brief

28 February 2013
This twenty-fourth edition features: Publications & Announcements Proposal for amendments to IAS 39 and IFRS 9 open for comment until 2 April 2013 International Accounting Standards Board - Latest Decisions Summary

RSM announces lead sponsorship of the European Business Awards

5 February 2013
RSM, the seventh largest global accounting network, has become the lead sponsor for the European Business Awards to April 2014. This is the sixth year in which RSM has supported the Awards programme, but the first time the network has chosen to become lead sponsor and spearhead the prestigious European awards.

RSM Survey of International Business Confidence

1 February 2013
This report summarises the results of a survey of international business confidence conducted at the RSM Annual Conference in London in November 2012. The survey gauged the views of over 280 senior leaders from within RSM member firms 70 countries on the following issues:

Issue 23 - IFRS News In Brief

31 January 2013
This twenty-third edition features: Publications & Announcements Proposal for amendments to IAS 36 open for comment until 19 March 2013 Proposed IFRS Taxonomy 2013 open for comment until 18 March 2013 IFRS Interpretations Committee - Latest Decisions Summary

Finalists for RSM Entrepreneur of the Year Awards announced

14 January 2013
The finalists for the highly-coveted RSM Entrepreneur of the Year award, one of the ten categories of the prestigious European Business Awards, have been unveiled.

ONE reveals diversification plan in response to retail grocery pressure

12 December 2012
The One brand, the European Business Award winning not-for-profit enterprise behind such products as ONE Water and ONE Eggs, is set to diversify away from high street retail as supermarkets come under increasing economic pressure.

Issue 14 - RSM Reporting

1 December 2012
This fourteenth edition features:

Audit process must adapt or risk being seen as irrelevant

19 November 2012
Auditors need to do much more to show that audit adds value, or risk the process being seen as irrelevant, according to a panel of experts debating the current state of the audit profession at the RSM annual conference last week in London.

Non-EEA Investment and Entrepreneurship in Ireland

1 November 2012
The Republic of Ireland is experiencing a slow recovery from the global credit crisis. Following a 10 percent GDP contraction in 2008-10, Ireland’s economy grew by 1.4 percent in 2011. Amid the global economic slowdown and the ongoing Euro crisis, the Irish economy is projected to grow by just 0.4 percent in 2012, rising to 1.1 percent in 2013.

RSM Middle East Firms Focus on Growth in Two-Day Regional Conference

25 October 2012
RSM, the world’s sixth largest network of accounting, tax and advisory firms, brought together managing partners from member firms in the Middle East to discuss growth opportunities in the region. Representatives from Morocco and Europe were also present.

Renewable Energy In Poland

1 October 2012
Poland is the European Union’s most coal-dependent economy. Coal represents over 80 percent of Poland’s national energy production and nearly 90 percent of its electricity generation. The outsized share of coal in Poland’s energy sector heightens pressure to develop renewable energy to meet the European Union’s 20-20-20 Directive.

United Kingdom: Proposed statutory residence test

1 October 2012
In June 2011, the UK Government launched a consultation document on the introduction of a statutory residence test which the government proposed to introduce in April 2012. This has now been delayed until 6 April 2013. The response to this consultation has recently been issued providing greater clarification.

Transfer Pricing: OECD Discussion Draft: Transfer pricing aspects of intangibles

1 October 2012
On 6 June 2012, the OECD published the first discussion draft for the revision of chapter VI of its transfer pricing guidelines.

Australia: Living Away From Home Allowance

1 October 2012
In an earlier edition of Border Crossing - 1st Quarter 2012 - we reported on significant and adverse changes to the Living Away From Home Allowance (LAFHA) provisions. Those changes have now been legislated, with effect from 1 October 2012.

United States of America: The application of the US FATCA rules to International Investment Funds

1 October 2012
In July 2009, the United States Department of Justice announced that it had reached a settlement with Swiss bank UBS under which the bank agreed to disclose the identities of over 50,000 US customers who used UBS accounts to commit US federal tax evasion.

Argentina: Termination of Argentina-Spain double taxation treaty

1 October 2012
On 29 June 2012, the Argentine government notified Spain that it had terminated the Argentina-Spain tax treaty for the Avoidance of Double Taxation (the treaty).

RSM network connects for day of global celebrations

19 September 2012
On 20 September 2012, RSM will bring together its accounting network of 32,000 colleagues across 700 offices in 94 countries as part of RSM World Day – a celebration of the growth and success of the integrated network and an opportunity to showcase its capabilities and expertise around the world.

Private Equity in the Post-Crisis Period

1 September 2012
Private equity acquired an unfavourable public reputation during the years preceding the 2008 financial crash. Critics indicted private equity houses for overleveraging distressed companies, stripping their assets and generating huge returns at the expense of company employees.

Issue 13 - RSM Reporting

1 September 2012
This thirteenth edition features:

Malta: High Net Worth Individuals Rules

1 June 2012
The High Net Worth Individuals Rules (the Rules) have recently been introduced to attract high net worth foreign individuals to take up residence in Malta and take advantage of the beneficial rate of tax. The Rules apply to both EU and third country nationals and will run in parallel to the current Residents Scheme Regulations.

Issue 12 - RSM Reporting

1 June 2012
This twelfth edition features:

China: Overseas Listed Companies ‘Share-based Incentive plans’

1 June 2012
On 20 February 2012, the PRC State Administration of Foreign Exchange (“SAFE”) issued Circular Huifa [2012] No.7 – ‘Notice regarding certain issues related to foreign exchange administration for individuals employed by domestic companies participating in share-based incentive plans of overseas listed companies’ (“Circular [2012] 7”).

Netherlands: New German-Netherlands tax treaty

1 June 2012
On 12 April 2012, Germany and the Netherlands signed a new tax treaty and protocol. The new tax treaty avoids double taxation and prevents fiscal evasion with respect to taxes on the income of residents. Furthermore, it regulates and improves the position of frontier workers. The new tax treaty has not yet been ratified.

Italy: Investment Funds Tax and Capital Gains Changes

1 June 2012
Introduction A new investment funds tax regime has been enacted in Italy meaning investment funds are no longer subject to tax on an accrual basis. Investors are instead taxed on a cash basis. Furthermore, from 1 January 2012 withholding tax and substitutive tax on interest, dividends and capital gains will be set at 20%.

USA: Proposed FATCA regulations

1 June 2012
On 8 February 2012, the IRS issued proposed regulations providing rules pursuant to the Foreign Account Tax Compliance Act (FATCA). The proposed regulations are generally consistent with the guidance set out in prior Notices. However, there are significant modifications and refinements.

UK: Worldwide Debt Cap

1 June 2012
Worldwide debt cap rules were introduced as an extension to the UK thin capitalisation rules to ensure that UK companies bear their fair share of group debt.  It applies to accounting periods beginning on or after 1 January 2010.

RSM Reveals New Brand

4 May 2012
RSM International, one of the world’s largest global accountancy networks, has revealed a new logo and shortened name to become RSM. Jean Stephens, CEO, RSM said, “This evolution of our name and brand mark reflects our growing connectivity and success as an integrated network.”

Dahman & Co. renames RSM Dahman

2 April 2012
The International Board of Directors of RSM International, one of the world's largest accounting, tax and advisory networks, has approved the use of the RSM prefix for Dahman & Co., its member firm in the UAE & Yemen. The firm will rename to RSM Dahman with immediate effect.

Issue 11 - RSM Reporting

1 March 2012
This eleventh edition features:

European Business Awards Open For Entries for 2012

31 January 2012
The European Business Awards, Europe’s toughest business competition, is now open for entries from businesses across the EU.

The Shale Gas Revolution

1 January 2012
Recent advances in hydraulic fracturing (“fracking”) are spurring development of shale gas reserves in the United States, Canada, Poland, Australia, and other countries. The shale gas boom has strengthened energy security in these countries by lowering dependence on imported fossil fuels.

Australia: Removal of FBT Concessions for Foreign Executives

1 January 2012
The Australian Government’s latest revenue raising measures are again targeting international businesses. The ‘Living away from home’ allowance and other related benefits have been denied concessional tax treatment for international employees along with increased substantiation requirements for all others. Background

South Africa: Transfer Pricing – A Significant Change

1 January 2012
With effect from 1 October 2011, South African Transfer Pricing legislation was significantly changed by the implementation of an amended Section 31 to the Income Tax Act 58 of 1962 (”the Act”). The section has now further been amended in terms of the Taxation Laws Amendment Bill 19 of 2011 introduced by the Minister of Finance on 25 October 2011.

USA: Foreign Investment in U.S. Real Estate

31 December 2011
Is there a “best” way for a foreign individual to own U.S. real estate?  When planning to acquire U.S. real estate, foreign individuals have a number of ownership alternatives to consider each of which offers its own advantages and disadvantages. There are other items a foreign investor should consider when evaluating the most advantageous method for holding U.S.

The Brussels Agreement: Fiscal Adjustment and Economic Growth in Europe

1 December 2011
On December 9, the European Council met in Brussels to devise a resolution of the Euro crisis that imperils the still fragile recovery from the global financial crisis.

Fallout of the Euro Crisis

5 November 2011
On 27 October 2011, the 17 Euro countries agreed to new €100 billion bailout package for Greece, which included a 50 percent write down of Greek government bonds held by private European banks.

Communication Infrastructure and Broadband Growth in Africa

1 November 2011
As the growth of Africa’s ICT (Information and Communications Technology) infrastructure proceeds, industry players are placing greater emphasis on mobile data and other value added services such as mobile banking and funds transfer.

Clean Technology in Europe

1 September 2011
Amid rising concerns about global climate change and growing anxieties over regional energy security, the European Union has launched a range of initiatives to spur adoption of clean technologies:

India as the Global Technology Hub

1 June 2011
Over the past two decades, India has become the global leader in offshore IT (Information Technology) and BPO (Business Processing Outsourcing) services. India’s IT/BPO industry is poised to reach annual revenues of US$225 billion by 2020.

Small and Medium Enterprises in the Global Economy

1 March 2011
Small and medium enterprises, which played a crucial role in job creation and economic growth in the early and mid-2000s, incurred major setbacks during the Great Recession. In the European Union, SME employment fell by over three million jobs in 2009-10.

Corporate Sustainability

1 February 2011
“Corporate Sustainability” – broadly conceived as the formal integration of economic, environmental, and social factors in managerial decision making and corporate governance – is assuming a central role in global business.

Renewable Energy in Europe 2010

1 November 2010
The development of renewable energy in Europe faces a host of environmental, economic and political hurdles. Imported fossil fuels represent more than half of European energy consumption. At projected growth rates, the share of imported hydrocarbons will rise to 70 percent of total energy consumption by 2020.

Economic Impact of the World Cup

1 August 2010
International sporting events offer significant potential benefits to host countries: modernization of infrastructure; upgrading of tourist facilities; increased foreign commerce; heightened global prestige and visibility.

German Exporters amid the Global Recovery

1 July 2010
On July 8, Germany’s Federal Statistics Office announced that German exports in May 2010 grew by 9.2 percent, their sharpest rise in 10 years. On seasonally adjusted balance, this result boosted German exports to €80.8 billion, just 5.4 percent below their pre-crisis peak.

Eurasia in the Global Economy

1 June 2010
Eurasia, the landmass bridging the traditional continents of Europe and Asia, has become a bulwark of the global economy.

Commercial Developments in MERCOSUR

1 May 2010
Since its creation in 1991, MERCOSUR (acronym in Spanish for Mercado Común del Sur or Common Market of the South) has been developing at an uneven pace.

International Tax Representation

1 April 2010
Companies planning to expand their international operations need to consider a wide variety of factors: Foreign demand for the company’s products and services;  transparency and cost efficiency of foreign subsidiaries; operating, investing, financing and non-cash expenses; and the impact of international expansion on the company’s aggregate tax burden.

The Smartphone and its Risks

1 March 2010
Having a few key safeguards in place can reduce the risk of smartphones becoming a matter of national security.

Australia: Cross-border transfer pricing reforms

12 June 2001
On 24 May, the Government introduced into Parliament the first piece of draft legislation in its reform of Australia’s transfer pricing provisions.