Chicago, USA

Tax Planning Spotlight: Qualified Small Business Stock

By Robert Jacobson, Kutchins, Robbins & Diamond, Ltd. (KRD)

Foreign nationals looking to start a business in the US often find that operating as a C Corporation is most desirable. One of the benefits of becoming a C Corporation is that they can issue Qualified Small Business Stock (QSBC). A QSBC is a US C Corporation that, upon sale, can have a 100% Federal capital gain exclusion for both regular and alternative minimum tax purposes.

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Rothenburg ob der Tauber, Germany

Regarding Non-Recognition of Profit Transfer Agreements: Infringement Proceeding Against Germany

By Brigitte Jakoby, Jakoby Dr Baumhof – Wirtschaftsprüfer Steuerberater Rechtsanwälte

On 25 July 2019, the EU Commission decided to initiate formal infringement proceedings against Germany regarding the non-recognition of profit transfer agreements which are in accordance with the laws of another EU member state. The background is that profit transfer agreements in Germany must be registered at the seat of the company. Furthermore, the contract must originally be concluded under German law – relevant to 291 AktG (Stock Corporation Act).

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Understanding Economic Substance

By Alun Griffths, Forward Group Limited

The Council of the EU adopted a resolution on a Code of Conduct for business taxation, the aim of which was counteracting the effects of zero tax and preferential tax regimes around the world. In 2017, the Code of Conduct Group (Code Group) investigated the tax policies of both EU member states and third countries, assessing:

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India an Attractive Investment Destination after Slashing of Corporate Tax Rates

By Bhavesh Jindal, Ashwani & Associates, Chartered Accountants

The history of the highest corporate tax rates in India goes back to 1997, with an effective corporate tax rate of 38.05%. However, in recent times, there has been a progressive shift in this trend, wherein India is becoming a more preferred nation for investment, bolstering investor sentiment by way of various regulatory and tax reforms. The central government, basing their optimistic approach on the main theme of “Made in India” as a means of nation building, has introduced a new tax regime, slashing the corporate tax rates in India by 8%, from the prevailing 30% to 22%. Even further, for a newly set up manufacturing company incorporated on or after 01 October 2019, the tax rates have been reduced to as low as 15%.

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Andorra

Andorra: A Little Paradise for Companies

By Josep Garcia, Advantia Assessors

The signing of agreements on the automatic exchange of information at the international level has removed Andorra from the list of tax havens, and it no longer features on the OECD blacklist.

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Cabo San Lucas, Baja California Sur, Mexico

Main Tax Implications for Foreign Investors in Mexico

By Mauricio Ramos Jimenez, Guerrero y Santana, S.C.

On 01 December 2018, Andrés Manuel López Obrador (or AMLO as he is commonly known) became president of Mexico after two consecutive unsuccessful presidential campaigns. AMLO has always had a leftist and populist agenda, and many feared he would make radical changes in several areas, including taxes, but what has really changed in the first months of his presidency? From a taxation perspective, not much has changed, at least not as a direct consequence of the new government.

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Rothenburg o. d. Tauber, Germany

Risk of German Limited Tax Liability Without Company Seat in Germany

By Brigitte Jakoby, Jakoby Dr Baumhof – Wirtschaftsprüfer Steuerberater Rechtsanwälte

The German Federal Fiscal Court (BFH) decided on 23 October 2018 that a company with a seat outside Germany becomes taxable in Germany if its manager has a private (second) home in Germany and is doing business for the company in Germany. In its decision, the BFH dealt with a limited capital company formed under the laws of Luxembourg. The business was conducted in Luxembourg by the managing partner. The business address in Luxembourg was also the private residence of the managing partner. But he also had a private residence in Germany and regularly visited the German suppliers in Germany.

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