Taxation

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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Taxation

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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Taxation

The international standard ruling procedure

By Dr. Sergio Finulli, Comma 10

The Italian tax agency's report of 19 March 2013 dealt at length with the international standard ruling procedure aimed at international companies which proposed to reach a preliminary agreement with the Italian tax authorities on

  • Determining fair market value in view of the transfer price rules (Article 110 para. 7 of Presidial decree 917/86)
  • The application proposed of rules also agreed for contracts in specific individual cases concerning paying or drawing dividends, interest, royalties and other elements of profits to or from non-resident rights holders;
  • The application proposed for specific individual cases of rules on attributing profits or losses to the stable organisational structure of a company domiciled in the territory of another state.

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Taxation

Encouraging innovation in the UK – the new Patent Box

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By Julie Bryant, Haines Watts

In April 2013, the UK Government introduced a new incentive for innovative high-tech companies to invest in the UK. In addition to the generous tax credits already available for qualifying research and development expenditure, there is now a "Patent Box" which allows companies to benefit from a reduced corporation tax rate of 10% on profits generated from qualifying patents. This new incentive further demonstrates the UK Government's desire to make the UK an attractive place to do business, and builds on other recent initiatives such as the dividend exemption, the reformed controlled foreign company rules and the reducing main rate of corporation tax.

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Taxation

Mexico "sugar tax" is in fact extensive tax reform

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By Sergio Guerrero Rosas, Guerrero y Santana, S.C.

After receiving the opinion of the Commission of Finance and Public Credit, last month the Mexican Congress approved the economic package proposed by President Peña Nieto on 8 September 2013. The package includes substantial amendments to, as well as the repeal and enactment of, various tax laws. The objective of the proposal is to generate employment and support the economy through a counter-cyclical effort. However, no programmes have been created or launched to stimulate investment or employment.

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Taxation

Trusts and international tax planning: a brief world tour perspective

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By Professor Robert Anthony, Graham Busch, Brigitte Jakoby, Nick Dornburg, Sergio Finulli, Fola Olaniyan, Robert R. Worthington, Angel Gabriel Viso, Ashish Bairagra and Ricky Wong, Independent member firms of GGI

The following article considers the efficacy of the trust as a means of tax planning, and considers how trusts are dealt with in a variety of jurisdictions.

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Taxation

OECD presents united front against aggressive tax optimization

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The revenue that states are losing due to international tax optimization by large companies is back into the focus of the Organization for Economic Co-operation and Development (OECD). According to the OECD study "Addressing Base Erosion and Profit Shifting", multinational corporations are eroding the tax base and disproportionately shifting their profits.

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Taxation

New Tax Regime in the Republic of Cyprus

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By Marios Eliades, M. Eliades & Partners LLC

The House of Representatives of the Republic of Cyprus has introduced new legislation relating to the intellectual property regime,  interest deductibility, group relief and deemed distribution of dividends. The new legislation became effective 1st January 2012.

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