By Béla Kakuk, BPiON Services Ltd.
One of the most important objectives of the international taxation regime is to allocate taxation where profit and value is generated in order to guarantee trust over truthfulness of tax regimes and effective taxation sovereignty of local governments. The European Unions Anti-Tax Avoidance (ATAD) (2016/1164/EU) directive brought new rules preventing tax evasion and aggressive tax optimisation.
By David Pritchard, Mander Duffill
This article focuses on the tax benefits of Research and Development (R&D) and making a claim through the small and medium-sized enterprises (SME) scheme. There is also a large company R&D scheme; however, it was felt that the SME scheme is likely to be of more relevance to GGI members.
By Andreas Hänggi, Treuhand-und Revisionsgesellschaft Mattig-Suter & Partner
The Swiss people voted “yes” at a referendum held on 19 May 2019, regarding the Swiss tax reform and AHV financing (“TRAF”). Based on this positive vote, Switzerland continues to offer a stable and reliable tax environment and remains one of the most attractive business and tax locations.
By Darlene Hart and James Debate, US Tax & Financial Services
A US Supreme Court ruling last June is expected to impact every company that sells goods or services into the US within months, or even weeks and days. In many places, it has already begun.
By Alex Barnes, Memery Crystal LLP
Between October 2018 and April 2020, there are various new changes of which clients need to be made aware. Some of these are anti- avoidance measures, some are to speed up HM Revenue & Customs’ (HMRC) collection of tax and some are new, or extensions to existing, reliefs. There will be opportunities and pitfalls. So, what are the changes?
By Prof Sergio Guerrero Rosas, Guerrero y Santana, S.C.
With the entry of the new government in Mexico led by President Andrés Manuel López Obrador, new foreign- investment opportunities seem to open up, mainly in the Mexican southeast and in the northern border area, so here is a brief summary of some tax credits and current incentives in Mexico.
By Anjali Kukreja and Raghu Marwah, R.N. MARWAH & CO. LLP
Foreign investment in Indian startups, especially in high technology areas of artificial intelligence and consumer-facing apps, offer a big opportunity. The start-up space in India offers a win-win scenario for all, as foreign investors multiply their investment values with high IRR’s and Indian start-ups provide increased jobs, digitalised lifestyle and improved product innovations contributing to a more vibrant and rewarding economy, as well as a positive social impact.
By Prof Robert Anthony, Anthony & Cie
I would just like to offer you a few thoughts concerning the evolution of legislation. As in many countries, France has been tightening up its laws to stop taxpayers from manipulating their affairs to avoid tax.
By Patrick J. McCormick, Drucker & Scaccetti
A threshold consideration sometimes inadequately explored by practitioners is how a foreign structure will be classified under United States tax rules. Frequently, advisors defer to foreign classification without fully examining details that could dictate alternative United States results. This article explores methods for determining classification, options for altering the default classification of an entity, implications of certain classification types, and considerations where the choice of entity classification is possible.
By Valeria Khmelevskaya, KBK Accounting
Nearly every Russian company belonging to multinational enterprises (MNE) has inter-company or cross-border arrangements or pays out dividends which might be especially attractive due to applicable double taxation treaty (DTT) incentives allowing reduced withholding tax rates or taxation only in the country of the recipient of such income. To apply such DTT incentives, a foreign recipient should provide a Russian company with the certificate of tax residency and confirmation of the recipient's actual right to such income prior to payment, otherwise the withholding tax (WHT) based on the Russian Tax Code shall apply (15% for dividends, 20% for other payments from Russian sources). Later on, a foreign company may still claim back the relevant WHT.
