San Jose, Silicon Valley

Structuring options for an investor’s US-based holdings

By Patrick McCormick, Offit Kurman, Attorneys at Law

Based on a number of factors, the United States increasingly serves as a magnet for foreign investment. Global perception of the US as a financial market is considerable – existing infrastructures and relative stability of financial institutions all make the US an attractive venue for foreign funds. An additional appeal of the United States is often favourable tax rules for foreign investors. When investments are structured properly, effective global tax rates – on income generated by the investment during ownership, on gains generated from the investment’s disposition, and on gratuitous transfers either during the lifetime or at the passing of the original owner – can be markedly lower than investments made in other well-established jurisdictions.

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Bucharest, Romania

SAF-T is a new entry for Romania in 2022

By Georgeta Petrescu, Savvy Audit & Finance

Standard Audit File for Tax (SAF-T) represents a new statement for Romanian companies in 2022. SAF-T reporting was developed by the OECD, which benefits not only tax authorities but also multinational entities. The structure proposed by the OECD was designed as an international standard, and should be considered as the minimum necessary to extract relevant information from an accounting system – each country being able to decide how to implement, and what level of detailed information will be transmitted through the SAF-T file.

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Global Minimum Tax Agreement

By Oliver Biernat (Benefitax GmbH ), Ashishkumar Bairagra (M L Bhuwania and Co LLP), and Alan Rajah (Lawrence Grant, Chartered Accountants)
The OECD has published detailed rules to assist in the implementation of a landmark reform to the international tax system, which will ensure Multinational Enterprises (MNEs) will be subject to a minimum 15% tax rate from 2023. The agreement has been signed by 136 countries representing more than 90 percent of global GDP.  

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G7 Nations to Set Minimum Global Corporate Tax Rate at 15%

By Bernhard Schwechel, FACT GmbH

The agreement builds on the twopillar approach outlined by the OECD and aims to tackle the challenges arising from an increasingly globalized and digital economy. Under Pillar One, the largest and most profitable multinational firms will be required to pay tax in the countries where they do business, rather than simply where the countries have headquarters or hold intangible property.

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Montevideio, Uruguay

The Free Trade Zones in Uruguay

By Diego Lasalvia and Ana Fernández, CARLE & ANDRIOLI Contadores Públicos

The Free Zones continue to be attractive to many international or local companies which establish operations here to provide global services and conduct commercial or industrial activities, highlighting regional logistics operations.

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Impact of Taxation on the Mobile Workforce – A Cobble Web

By Bhavesh Jindal, Ashwani & Associates

With the advent of technology and single table office scenarios in the current pandemic driven economy, the veil of location and time barriers has dropped. This has given rise to work from home (WFH) culture and a workforce that can operate from anywhere, at any time.

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Lausanne, Switzerland

Novelties in the Swiss Tax at Source

By Cédric-Olivier Jenoure and Sascha Wohlgemuth, Bratschi Ltd.

Multiple novelties and changes in the Swiss tax at source hold risks for companies and groups concerning the correct declaration of the income of employees who are foreign residents without settlement permits. Companies, as employers who are liable for the payment of the tax, must take the following into account:

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London, UK

Reverting to the Two-Tier System

By Deborah Nadav, Citroen Wells Chartered Accountants

Since 01 April 2015, the UK has had one flat rate of corporation tax, currently 19%. This is set to change effective 01 April 2023, with the Finance Act 2021 reintroducing the small profits rate. The main rate of corporation tax will increase to 25% for companies with profits over GBP 250,000 and a small profits rate of 19% will apply to most companies with profits up to GBP 50,000. Companies earning profits of between GBP 50,000 and GBP 250,000 will apply marginal relief.

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