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.
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?
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.
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.
By Robert S. Jacobson, Kutchins, Robbins & Diamond, Ltd.
Research and Development (R&D) is often associated with sophisticated laboratory experimentation where cuttingedge technological product is created. However, the Internal Revenue Code offers a more flexible definition of research and development.
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.
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.
By Alejandro Fernando Toulet Lazos and Bridget Guzman, Toulet, Gottfried, Dávila y Martínez, S.C.
Currently, maquiladoras entities import their raw materials into Mexico and thereafter export a finished product. However, what happens if instead maquiladoras sell their products into the Mexican domestic market?
By Roberto M. Cagnazzo, Studio Tributario Cagnazzo
The Italian Budget Law 2018 has introduced substantial modifications to the domestic definition of permanent establishment (PE). The changes consist mainly in the redefinition of the traditional classification and criteria for the identification of the ‘material’ and ‘personal’ PE. The lawmaker has made these changes in line with the new provisions of the OECD Base Erosion and Profit Shifting project (BEPS), the OECD Model Tax Convention on Income and on Capital and the OECD Multilateral Convention to Implement Tax Treaty Related Measures to Prevent BEPS.
By Saul Jimenez, Kutchins, Robbins & Diamond, Ltd. (KRD)
The items below detail various types of U.S. stock options that can be made available to staff and management. An interested company will need to have a valuation performed annually to determine the value of the company’s stock in order to properly account for any of the options below.
