By David Lechem, Stephen Jankelowitz and Robert Moylan, Ageis
In this global world, incentives are offered by some countries to encourage investment and immigration. Australian tax residents are taxed on worldwide income including income from assets held indirectly through interests in foreign companies or trusts. In 2006, Australia introduced a regime where Australian tax residents who are temporary residents can apply significant tax concessions in respect of their foreign income and gains.
By Tony Nunes and Isabella Chin, Kelly + Partners Chartered Accountants
An employee incentive scheme (EIS) is a scheme under which shares or rights to acquire shares in a company are provided to an employee or their associates in relation to the employee’s employment.
By Niels Webersinn, nbs partners
In Germany, there is a saying with regard to legal proceedings – on the high seas and in court, you are in God's hands. Despite all the efforts of the tax advisors and lawyers to pursue fundamentally promising paths with clients and to take realistic procedural steps in order to protect them from unnecessary adversity, the statement proves true time and again.
By Ingo Prang and Marcus Rösen, KPP Steuerberatungsgesellschaft mbH
The German Federal Fiscal Court (BFH) had submitted a request for a preliminary ruling to the European Court of Justice (ECJ) regarding the deduction of so-called final losses for EU foreign permanent establishments (PEs). In the most recently published ruling of 09 September 2022 (ref. C-538/20), the ECJ ruled that the freedom of establishment does not preclude the non-deductibility of final losses in EU-exemption PE cases.
By Valeria Khmelevskaya, KBK Accounting
A number of countries have put international tax cooperation with Russia on hold. This has inadvertently led to negative consequences for both Russian and foreign tax residents.
By Cédric-Olivier Jenoure and Sascha Wohlgemuth, Bratschi Ltd.
In Switzerland on 01 January 2023 the new stock corporation law came into force. One change is that stock corporations and limited liability companies may express their nominal capital not only in Swiss francs (CHF), but also in EUR, USD, GBP, or JPY if this is their functional currency. However, it is mandatory that at the time of incorporation the equivalent value is at least CHF 100,000 for stock corporations, and CHF 20,000 for limited liability companies.
By Eddie Lee, Robert Yam & Co. PAC
Transfer Pricing (“TP”) is an essential aspect of the regulatory requirements in Singapore for companies which have intra-group transactions or related party transactions (“RPTs”) in Singapore and if they expand their businesses outside Singapore. TP rules require that those RPTs are conducted at arm's length prices, which refers to prices that would be agreed upon by unrelated parties in similar situations.
By Gary Williams, Rosenfeld, Kant & Co.
Since a major overhaul of Australia's screen industry tax incentives in 2008, television and film makers from around the world have been attracted to Australia for producing content, accessing post- production facilities, and/or using Australia as a filming location.
By Tony Nunes and Susan Ma, Kelly + Partners Chartered Accountants
In the October 2022 Federal Budget, the Australian government announced potential changes to Australia's thin capitalisation rules to adopt the OECD's recommended approach in BEPS Action 4. A draft legislation is currently undergoing a consultation process until 13 April 2023 (the Draft). The changes, if enacted, will apply to multinational business operating in Australia (except banks and financial entities) with at least AUD 2 million in tax deductions for interest expenditures, for income years commencing on or after 01 July 2023.
By Carla Smith, Nolands SA
On 17 January 2023, the South African Revenue Service (SARS) published Interpretation Note 127 (IN127). The note covers several topics and offers taxpayers long-awaited guidance on the application of the arm’s length principle as it relates to the pricing of intra- group loans.