RSM Global

Tax

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.  

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?”

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.

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 

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.

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