Harbour USA

Will the new US tax law affect your business?

By James Debate, US Tax & Financial Services Group Ltd.

Taxation is consistently described as one of the biggest concerns for businesses that are looking to expand into the US. At 35%, the US used to have a corporate tax rate that was among the highest out of the world’s developed economies. Add to that a complex tandem of federal and state regulation, and a system of global taxation on USdomiciled companies, and the result is that setting up a business in the US can be an onerous process.

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New decision of the ECJ regarding triangular operations

By Brigitte Jakoby, Jakoby Dr Baumhof - Wirtschaftsprüfer Steuerberater Rechtsanwälte

The case in question concerns triangular operations of the German company Hans Buehler KG. The company has a German as well as an Austrian VAT-ID-No. Buehler applied the latter when it was a first customer in triangular operations.

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Brexit: Your Client Needs You

By Steve McCrindle, Haines Watts

With Brexit set for 29 March 2019 and with no approved agreement yet between the EU and the UK on post-Brexit VAT, Customs and Border conditions, what have your affected clients done to prepare?

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Italy: Guidelines for the Application of the Transfer Pricing Provisions

By Roberto M. Cagnazzo, Studio Tributario Cagnazzo

On May 2018, the Italian Minister of Economy and Finance (MEF) issued a Decree containing the domestic guidelines on transfer pricing provisions and the arm’s length principle. The guidelines are part of the process of adapting the Italian tax law and practice to the principles outlined in the OECD BEPS Project and already incorporated in the Guidelines 2017.

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Investing in Qualified Opportunity Zones

By Detelina Staneva, Kutchins, Robbins & Diamond, Ltd. (KRD)

The Tax Cuts and Jobs Act signed into law on December 22, 2017 contains new tax incentives for long-term investments in low-income communities designated as Qualified Opportunity Zones (QOZ). The new QOZs provide incentives to investors to defer recognition of current investment gains from sales to unrelated parties, if those gains are reinvested in designated low-income areas.

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UK Tax Changes to Foreigner’s Trusts

By David J. Kidd, Citroen Wells Chartered Accountants

Never-ending change: The UK Treasury cannot keep from changing the UK tax rules affecting foreigners, often referred to technically as ‘foreign domiciliaries’. At the time of the last major upheaval in 2008, there was a Treasury promise that there would be no further changes. In fact, there have been changes every year following 2008.

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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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