Taxation

New Dividend tax in India may impact foreign companies (2)

By Raghu Marwah and Anjali Kukreja, R.N. Marwah & Co LLP

1. Introduction of new law and its amendment

Before the insertion of section 115BBDA, there was loss to revenue, as high dividend income recipients (individual, HUF or firm) who would have been taxed at 30% had their tax liability discharged through DDT in the hands of the company at around 15%. Hence, to plug this loss of revenue, the Finance Bill 2016 inserted section 115BBDA into the Income Tax Act 1961 (hereafter the ‘Act’) with effect from 1 April 2017.

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Taxation

Italy: an updated definition of Permanent Establishment

By Roberto M. Cagnazzo, Studio Tributario Cagnazzo

The Italian Budget Law 2018 has introduced substantial modifications to the domestic definition of permanent establishment (PE). The changes consist mainly in the redefinition of the traditional classification and criteria for the identification of the ‘material’ and ‘personal’ PE. The lawmaker has made these changes in line with the new provisions of the OECD Base Erosion and Profit Shifting project (BEPS), the OECD Model Tax Convention on Income and on Capital and the OECD Multilateral Convention to Implement Tax Treaty Related Measures to Prevent BEPS.

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Assurance

Types of Employee Stock Options

By Saul Jimenez, Kutchins, Robbins & Diamond, Ltd. (KRD)

The items below detail various types of U.S. stock options that can be made available to staff and management. An interested company will need to have a valuation performed annually to determine the value of the company’s stock in order to properly account for any of the options below.

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Taxation

The Calm before the Storm

By Sergio Guerrero Rosas, Guerrero y Santana, S.C.

It’s true that it has been a slow year in taxation but we can’t take our minds off what is yet to come for Mexico; major changes will be happening and we have to be prepared for them.

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Taxation

The preparation of annual accounts for a French SCI is required for tax reasons

By Prof Robert Anthony, Anthony & Cie

The question of preparing annual accounts for an SCI (Société Civile Immobilière) appears to be clear under French domestic tax law. Some foreign and French resident clients contacted us wondering whether accounting should be held for a French SCI. These clients have had different replies from different practitioners. The purpose of this article is to show the necessity for tax purposes to hold annual accounts.

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Taxation

Need for an Effective Tax Compliance System in Germany?

By Bernhard Schwechel, FACT GmbH

Germany’s Tax Authorities issued a decree in 2016 on the procedure for amending a tax return under sec. 153 of the General Tax Code (AO). It raised the issue of an internal control system for tax purposes and contains general guidance about the conditions that must be fulfilled to use the provision, as well as the criteria for distinguishing between a simple amendment procedure and a voluntary self-disclosure procedure (VSP).

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Taxation

Budget 2018 dodges on amalgamation path of tax avoidance

By CA Anjali Kukreja, RN Marwah & Co LLP Chartered Accountants

Tax law before Budget 2018 amendment: Provisions of section 115-O of the Income Tax Act, 1961(„Act‟) provide for application of Dividend Distribution Tax („DDT‟) @ 15% (plus applicable surcharge and cess) on the amount of dividend (declared distributed or paid by a domestic company). Further, provisions of section 115-Q provide that the expression dividend for the purpose of section 115-O would include deemed dividend under section 2(22)[sub-clauses (a),(b),(c) and (d)] of the Act.

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Taxation

Heidelberg

The BEPS Multilateral Instrument

By Heike Kempf, WSB Wolf Beckerbauer Hummel & Partner Steuerberatungsgesellschaft mbH

The OECD Base Erosion and Profit Shifting (BEPS) Programme involves over a 100 countries collaborating on its implementation. BEPS Action 15 is the development of The Multilateral Convention to Implement Tax Treaty Related Measures to Prevent Base Erosion and Profit Shifting (MLI). Countries can use the MLI to implement various treatyrelated measures.

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