The New UK CFC Rules – A Brief Overview

By David J Kidd, Citroen Wells

After a long period of consultation, the UK controlled foreign company (CFC) rules have been substantially overhauled. The new legislation applies for accounting periods beginning after 1st January 2013. This means that implementation at a detailed compliance level is now beginning for the first time for many UK companies. Thus a brief overview of the essential elements of the new rules may be of interest.

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Czech R&D tax incentives

By Richard Jahoda, Grinex Czech Republic

The Czech Republic strives to attract high-tech businesses and to support research & development projects. It therefore offers two different types of tax incentive.

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Changes in corporate taxation in Switzerland

By Marc Nideröst, Treuhand- und Revisionsgesellschaft Mattig-Suter & Partner

Switzerland is one of the most attractive locations for domiciles in Europe. The effective corporate tax rate varies between 11.6% of pre-tax profits in Wollerau, Canton of Schwyz (often seen as one of the most favourable tax municipalities in Switzerland), to 24.1% of pre-tax profits in the City of Geneva. The average corporate tax rate is at 17.92% of pre-tax profits (base 2014).

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Challenges in transfer pricing (TP) documentation

By Ashish Bairagra,M. L. Bhuwania & Co.

While TP regulations evolve around the world, it is extremely difficult for companies to judge the expectations of the tax authorities with respect to TP documentation. The need to defend the arm’s length price of transactions in the TP documentation has increased due to the intense global spotlight on what is now called “Base Erosion and Profit Shifting” (BEPS).

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Poland introduces CFC and GAAR

By Artur Plutowski, EFS Group Sp.z.o.o.

The Polish Minister of Finance announced a package of tax reforms to be implemented in the coming years, covering CIT, PIT and VAT among others. The aim is to significantly reduce tax planning opportunities through the introduction of both the Controlled Foreign Corporations (CFC) concept and the General Anti-Avoidance Rule (GAAR), as well as others including changes  to thin capitalisation and transfer pricing. The following presents brief comments on CFC, GAAR and thin capitalisation.

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Goods and Services Tax in Malaysia

By KC Chia, KC Chia & Noor

“Journey of a thousand miles begins with a single step […] It does not matter how slowly you go as long as you do not stop.” Confucius - The Malaysian government will follow in the footsteps of more than 160 countries worldwide by implementing the Goods and Services Tax (GST), which will become effective from 1 April 2015, giving a lead time of approximately nine months for businesses in Malaysia to prepare and comply.

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A Practical Guide to The Department of Treasury’s Amendment

By Peter J. Scalise, Prager Metis International LLC

The United States Research and Experimentation Tax Credit (hereinafter “RTC”) Program was added to the U.S. Internal Revenue Code (hereinafter “I.R.C.”) in 1981 to incentivize qualified research and development expenditures within the United States and its possessions (e.g., United States Virgin Islands, Puerto Rico, Guam, etc.). As a direct result of the overwhelming success of the program at the Federal-level, most states now offer a research tax incentive (e.g., credit or deduction) as well. These combined Federal and Multi-State research tax incentives exponentially help companies tax effect their actual expenditures to design and develop their next generation “best in class” products as well as their manufacturing process improvements.

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