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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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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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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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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By Sati Virdee, Citroen Wells Chartered Accountants
The Trust Registration Service (TRS) is a register of the beneficial ownership of trusts. The requirement to register applies to UK and some non-UK trusts, with some exclusions, regardless of whether the trust is liable to pay any tax.
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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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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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By Matteo Bedogna, Baldi & Partners Avvocati e Commercialisti
From a tax point of view, the new patent box regime makes R&D activities particularly profitable for companies located in Italy.
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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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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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