By Bernhard Schwechel, FACT GmbH
In the context of a share deal, a large part of the acquisition costs is usually financed by borrowing. A positive leverage effect can be achieved through a so-called debt push-down by combining the interest expenses of the acquirer with the operating results of the target company. In this situation, the company to be acquired virtually buys itself. In order to ultimately ensure a tax-optimised acquisition, there are a number of other considerations in addition to deductible acquisition financing. Taking into account the latest legislative developments on real estate transfer tax tightening for share deals, the downstream merger will be presented as one method of debt push-down.
By Tony Nunes, Kelly + Partners Chartered Accountants
Although the ATO’s approach to country-by-country (CbC) reporting is mostly consistent with OECD’s BEPS Action 13, there are several differences that are easy to overlook. For significant global entities (SGEs) operating in Australia, these are important to note, especially as significant penalties may apply.
By Philipp Schmidig, Treuhand- und Revisionsgesellschaft Mattig-Suter & Partner
The authorisation required for withholding tax reporting procedure in international relations will be valid for five years instead of three years, as of 01 January 2023.
By R. Oliver Branch and Aasim Hirji, Moodys Tax Law LLP
Regardless of what you might hear in a slick marketing pitch by one of the behemoth law and advisory firms, strategic global mobility planning is not a one-size-fits-all endeavour. When assisting a private business expansion across borders, a strategic, jurisdictionally-specific approach is required to ensure that you don’t solve one problem while unintentionally leaving your client with a handful of new problems.
By Chirag V and Aditya Sriram R, VCAJ & Associates LLP
In 2015, the Government of India announced establishment of Gujarat International Financial Tec-city (“GIFT City”), in Gujarat as India’s First International Financial Services Centre(“IFSC”). The IFSC in GIFT City seeks to bring to the Indian shores, those financial services transactions currently undertaken outside India by overseas financial institutions.
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.
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.
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.
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.
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.