RSM Global

Tax

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.

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:

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.  

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.

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.

Italian voluntary disclosure for individuals resident in Ita

1 April 2015
On 15 December 2014, the Italian Parliament approved the 'voluntary disclosure' procedure (Law n. 186/2014).

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