Chicago, USA

Understanding the Foreign-Derived Intangible Income Deduction (FDII)

By Howard Bakrins, Kutchins, Robbins & Diamond, Ltd. (KRD)

US corporations that generate income from export activities should consider if the foreign-derived intangible income (FDII) deduction applies. The Tax Cuts and Jobs Act (TCJA), passed in 2017, made significant changes to the taxation of foreign income of US businesses. One of these changes was the creation of the FDII deduction.

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Ice skater in New York Central Park

Downward Attribution: An Uphill Battle?

By Joanne Fay, Funaro & Co. PC

Non-US businesses may do business in the US through US corporations, especially “blockers”. The Tax Cuts and Jobs Act in 2017 created a surprising new regime for certain US subsidiaries in foreign-parented groups. Depending on the group’s structure, certain non-US subsidiaries may now be deemed to have US shareholders, and that creates the risk of unplanned Subpart F, Section 965, and GILTI income inclusions until the US Congress fixes the problem.

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Vintage tram in the centre of the Old Town of Milan

Direct Application of EU General Anti-Abuse Rule

By Dr Sergio Finulli; COMMA 10 Chartered Accountants & Lawyers

The EU ATAD (European Union Anti-Tax Avoidance Directive) No. 2016/1164 introduced a general anti-abuse rule in Article 6 that not only replaces and standardises the anti-abuse rules included in the three directives which regard corporate income tax (company mergers, parentsubsidiary, interest and royalties), but also extends the scope in the national legislations of the member states.

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online trade

Operators of Internet Marketplaces are Liable for the VAT of Their Traders

By Susann Roll, Benefitax GmbH

International online trade has become a huge business sector, in which it is often easy for traders to avoid VAT payments for sales, which are in fact VAT liable. To make VAT fraud more diffcult, new German legislation came into effect on 01 January 2019, which makes electronic marketplaces like Amazon and eBay liable for the VAT liability of the traders using their platform.

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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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