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.
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By Marc Nideröst, Treuhand- und Revisionsgesellschaft Mattig-Suter und Partner
With respect to Switzerland's intercantonal and international tax law, a company generally is not considered to have a permanent establishment in Switzerland or in another canton simply because employees are working from home there. However, as is so often the case, here too the exceptions prove the rule.
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By Darlene Hart, USTAXFS
For about 20 years now, the IRS has been annually publishing a ‘Dirty Dozen’ list of common taxpayer “scams.” The intent is to warn taxpayers, tax professionals, financial institutions, and financial advisors of abusive transactions, including bogus tax avoidance strategies as well as consumer- focused scams that target average taxpayers.
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By Roberto M. Cagnazzo, Three & Partners
The Italian Revenue Agency has provided guidelines on transfer pricing. To comply with the arm’s length principle, the Agency has emphasized that it is important to consider the range of values formed by the financial indicators selected in application of the most appropriate method applicable to each transaction between independent third parties, comparable with the controlled transaction.
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By Bhavesh Jindal, Ashwani & Associates Chartered Accountants
Decentralised blockchain transactions have gained worldwide traction especially in the post-pandemic era. However, the global economy is still coping with the challenges of the existing digital world (Web 2.0), which led to introduction of concepts like significant economic presence and minimum global tax to collect tax in a source jurisdiction where companies operated digitally without any physical presence. The trend of offbeat technological frontiers has now raised the question of how to manage an entire parallel universe (a.k.a. the metaverse). A more humanised version of internet applications, the metaverse will provide spatial experiences comparable to those in the real world by enabling decentralised interactions between users.
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By Prof Sergio Guerrero Rosas, Guerrero y Santana, S.C.
In March 2021, the Mexican Congress, at the initiative of President Lopez Obrador, passed a reform to the Mexican Electricity Industry Law, thus bringing an end to almost 10 years of open market/ renewable energy-oriented policy. This latest constitutional reform dismantles the former administration´s 2013 energy reform and all subsequent actions taken by both state and private actors.
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By Niels Webersinn, nbs partners
From a tax perspective, the end of 2022 in Europe resembled a highly exciting high-noon duel. Even after the United States launched an atomic tax bomb by terminating its joint double taxation agreement with Hungary, Hungary maintained its refusal to implement the global minimum taxation rules as per the EU directive. The 06 December 2022 meeting of the EU Council of Finance Ministers (ECOFIN) also did not result in any change.
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By Cédric-Olivier Jenoure and Sascha Wohlgemuth, Bratschi Ltd.
Effective 01 January 2023, more flexible formation rules and capital requirements will apply to public limited companies in Switzerland. The capital band, a new legal institution, is intended to make the procedures for increasing and reducing share capital more flexible.
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By Bernhard Schwechel, FACT GmbH
In the context of a share deal, a large part of the acquisition costs is usually financed by borrowing. A positive leverage effect can be achieved through a so-called debt push-down by combining the interest expenses of the acquirer with the operating results of the target company. In this situation, the company to be acquired virtually buys itself. In order to ultimately ensure a tax-optimised acquisition, there are a number of other considerations in addition to deductible acquisition financing. Taking into account the latest legislative developments on real estate transfer tax tightening for share deals, the downstream merger will be presented as one method of debt push-down.
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By Tony Nunes, Kelly + Partners Chartered Accountants
Although the ATO’s approach to country-by-country (CbC) reporting is mostly consistent with OECD’s BEPS Action 13, there are several differences that are easy to overlook. For significant global entities (SGEs) operating in Australia, these are important to note, especially as significant penalties may apply.
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