Liberty Bridge in Budapest

EU ATAD Imple­men­tation in Hungary – Corporate Income Tax 2019

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.

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 Research and Development

How can Research and Development provide a tax benefit?

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.

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Swiss Alps with Matterhorn

Switzerland Remains One of the Most Attractive Tax Locations

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.

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The UK Real Estate Tax Landscape is Changing

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?

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research and development (R&D)

Mexican Tax Credits and Incentives

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.

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Indian Start-up

Foreign Investment in Indian Start-Ups

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.

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How is my interest classified for US tax purposes?

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.

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Beneficial ownership concept and how this could affect your business in Russia

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.

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