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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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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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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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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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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German Tax Regulations on Hidden Reserves come before the EuGH


The German tax regulations that govern the reinvestment of hidden reserves cannot be reconciled with European law. This at least is the opinion of the European Commission, which has therefore sued Germany in the European Court of Justice (EuGH). The suit filed before the EuGH is the final step in treaty violation proceedings.

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The UK’s secret international trading vehicle

By Graham Busch, Lawrence Grant

Come in James Bond? Shaken not stirred? Well, to be honest, the vehicle to which I refer is not 007's Aston Martin. Nothing quite so glamorous. Nonetheless, a very interesting opportunity for international traders wishing to use a UK entity that offers limited liability in a potentially (entirely) UK tax-free environment. I am talking here about the UK Limited Liability Partnership, or LLP.

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Poland has become a tax haven

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By Artur Plutowski, EFS Group


The latest issue of Der Spiegel (German weekly magazine) awarded Poland the European Champion due to the excellent performance of the Polish economy which has achieved GDP growth over last 6-8 years. In that period Poland became a very attractive investment location. In the last months Poland became even more attractive; it became a tax haven. Savings can be achieved by the implementation of structures including a vehicle in the form of a Limited Joint Stock Partnership (the 'Partnership').

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UK Budget Changes Affecting UK Property

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By David J Kidd, Citroen Wells Financial Audit & Accountancy Services


London as favoured location? There was a recent report that London and New York are still the favoured places for the world's wealthy to buy houses, but competition is growing from Beijing and Dubai. Quality of life and economic activity were, according to the report, among key factors for the wealthy in choosing where to invest. London came top of the list in most factors and was still expected to be top of the list in a decade's time. This report was prepared prior to the UK Budget on 21st March 2012 when adverse tax measures, uncertain in detailed scope, were announced; and it remains to be seen whether London can continue to be a favoured place. This article covers the main changes.

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