By Dr Sergio Finulli, COMMA 10
Italy has recently adjusted the tax legislation for companies which transfer their headquarters from Italy to a foreign country (exit tax) and for foreign companies which move to Italy.
By Robert Jacobson, Kutchins, Robbins & Diamond, Ltd. (KRD)
Foreign nationals looking to start a business in the US often find that operating as a C Corporation is most desirable. One of the benefits of becoming a C Corporation is that they can issue Qualified Small Business Stock (QSBC). A QSBC is a US C Corporation that, upon sale, can have a 100% Federal capital gain exclusion for both regular and alternative minimum tax purposes.
By Bernhard Schwechel, FACT GmbH
Pillar Two calls for a coordinated set of rules to address ongoing risks from structures that allow multinational entities (MNEs) to shift profits to jurisdictions where they are subject to no or very low taxation:
By Brigitte Jakoby, Jakoby Dr Baumhof – Wirtschaftsprüfer Steuerberater Rechtsanwälte
On 25 July 2019, the EU Commission decided to initiate formal infringement proceedings against Germany regarding the non-recognition of profit transfer agreements which are in accordance with the laws of another EU member state. The background is that profit transfer agreements in Germany must be registered at the seat of the company. Furthermore, the contract must originally be concluded under German law – relevant to 291 AktG (Stock Corporation Act).
By Richard Mander, Mander Duffill
There are two changes which affect the amount of capital gains tax (CGT) due on sales of UK residential property after 06 April 2020:
By Alun Griffths, Forward Group Limited
The Council of the EU adopted a resolution on a Code of Conduct for business taxation, the aim of which was counteracting the effects of zero tax and preferential tax regimes around the world. In 2017, the Code of Conduct Group (Code Group) investigated the tax policies of both EU member states and third countries, assessing:
By Bhavesh Jindal, Ashwani & Associates, Chartered Accountants
The history of the highest corporate tax rates in India goes back to 1997, with an effective corporate tax rate of 38.05%. However, in recent times, there has been a progressive shift in this trend, wherein India is becoming a more preferred nation for investment, bolstering investor sentiment by way of various regulatory and tax reforms. The central government, basing their optimistic approach on the main theme of “Made in India” as a means of nation building, has introduced a new tax regime, slashing the corporate tax rates in India by 8%, from the prevailing 30% to 22%. Even further, for a newly set up manufacturing company incorporated on or after 01 October 2019, the tax rates have been reduced to as low as 15%.
By Josep Garcia, Advantia Assessors
The signing of agreements on the automatic exchange of information at the international level has removed Andorra from the list of tax havens, and it no longer features on the OECD blacklist.
By Mauricio Ramos Jimenez, Guerrero y Santana, S.C.
On 01 December 2018, Andrés Manuel López Obrador (or AMLO as he is commonly known) became president of Mexico after two consecutive unsuccessful presidential campaigns. AMLO has always had a leftist and populist agenda, and many feared he would make radical changes in several areas, including taxes, but what has really changed in the first months of his presidency? From a taxation perspective, not much has changed, at least not as a direct consequence of the new government.
By Brigitte Jakoby, Jakoby Dr Baumhof – Wirtschaftsprüfer Steuerberater Rechtsanwälte
The German Federal Fiscal Court (BFH) decided on 23 October 2018 that a company with a seat outside Germany becomes taxable in Germany if its manager has a private (second) home in Germany and is doing business for the company in Germany. In its decision, the BFH dealt with a limited capital company formed under the laws of Luxembourg. The business was conducted in Luxembourg by the managing partner. The business address in Luxembourg was also the private residence of the managing partner. But he also had a private residence in Germany and regularly visited the German suppliers in Germany.
