Sydney, Australia

Australian Temporary Resident Rules

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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Kassel, Germany

Debt push-down application under BEPS regulations in Germany

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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Sydney, Australia

The onerous Australian country-by-country reporting obligations

 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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The three pillars of cross- border expansion – Canadian private business expansion to the United States

By R. Oliver Branch and Aasim Hirji, Moodys Tax Law LLP

Regardless of what you might hear in a slick marketing pitch by one of the behemoth law and advisory firms, strategic global mobility planning is not a one-size-fits-all endeavour. When assisting a private business expansion across borders, a strategic, jurisdictionally-specific approach is required to ensure that you don’t solve one problem while unintentionally leaving your client with a handful of new problems.

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Chennai, India

Financial Service Sector in India – Changing Landscape 2022

By Chirag V and Aditya Sriram R, VCAJ & Associates LLP

In 2015, the Government of India announced establishment of Gujarat International Financial Tec-city (“GIFT City”), in Gujarat as India’s First International Financial Services Centre(“IFSC”). The IFSC in GIFT City seeks to bring to the Indian shores, those financial services transactions currently undertaken outside India by overseas financial institutions.

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vidhana soudha, Bangalore, India

India’s tax reforms on BEPS Pillar 1 and Pillar 2

 By Ishita Bhaumik, JAA & Associates

With liberalisation and spread of businesses across jurisdictions, global norms are becoming more relevant when determining profit allocation and taxability. The OECD recently announced the Pillar Two guidelines for discussion, and in December 2021 the model rules for base erosion were tabled. Pillar One aligns taxation rights more closely with local market engagement. Pillar Two establishes a global minimum taxation regime through a series of interlocking set of rules.

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Turin, Ttaly

International mergers and Italian anti-abuse regulations

By Roberto M. Cagnazzo, Three & Partners

The Italian tax authorities have recently published some interesting responses in tax rulings concerning international reorganisation operations. In one of these rulings, the situation was examined of a group with a parent company and a sub-holding company both resident in France, and three operating companies resident in Italy.

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Den Bosch, The Netherlands

Hiring from abroad in the Netherlands

By Carijn van Helvoirt–Franssen and Roel Jansen, EJP Financial Astronauts

When expats come to The Netherlands to work and live, they often have double costs – the so-called extraterritorial costs. Examples of these costs are housing costs, insurance, etc.

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Moscow, Russia

Disclosure obligations for foreign entities in Russia extended in 2022

By Valeria Khmelevskaya, KBK Accounting

Based on Russia’s federal law No. 115-FZ On Anti-Money Laundering and Combating the Financing of Terrorism, the majority of Russian companies are obliged to maintain and update a register of beneficial owners, but such information may be disclosed only upon request of the competent state bodies – tax authorities, Rosfinmonitoring (the Russian Federal Financial Monitoring Service), banks, etc.

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