Taxation

German fiscal unity taxation: with a sub-subsidiary

By Bernhard Schwechel, FACT GmbH

Multinational groups often hold their domestic and foreign sub-subsidiaries by an intermediary holding company, which is resident in a different country (e.g. Luxembourg) to its parent company (Germany). In this case, a tax-optimised profit repatriation from the sub-subsidiaries to their grandparent company depends on the conditions of the double tax treaties (DTA). But often, due to anti-treaty shopping rules, the foreign intermediary holding is not able to benefit from a reduced withholding tax rate stipulated in the DTA.

Continue Reading

Taxation

How Mexico has implemented the BEPS Action Plan

By José Carreras Benitez, Integroup S.C.

The Mexican economy is and has consistently been growing as a result of the rapid expansion of the middle class due to education and the maturing of Mexico as an economic powerhouse. Companies from Europe and the USA are investing billions of dollars into the Mexican economy. Mexican government knows that global businesses are coming and the Base Erosion and Profit Shifting (BEPS) Action Plan suggestions have been implemented in order to protect the tax system as well as giving same protection to the Mexican partners of the Organisation for Economic Co-operation and Development (OECD). Below is a brief description of one of them:

Continue Reading

Taxation

The New Italian Patent Box Regime (Art.1 paragraph 36 to 45 of Law no.190 of 2014)

By Dr Massimiliano Russo, Studio Signori

After a recent debate as to the possible introduction of new tax tools and incentives to attract foreign investments in Italy as well as a long period in which we have seen measures increasing the tax burden for both companies and individuals, this newly introduced legislation on the Patent Box Regime as a tax incentive is most welcome (in the following also referred to as the “incentive”). Unfortunately, as with most the newly introduced legislation in Italy, some aspects have not yet been committed and will be further regulated in future ministerial decrees. The interpretation of the newly introduced rule by tax  authorities is also still awaited.

Continue Reading

Taxation

IHQs & ITCs: New incentives for Thailand or just a change of letters?

On 1st May a Royal Decree was published,  implementing incentives for companies establishing their international headquarters (IHQ) and international trading centres (ITC) in Thailand. The idea behind the scheme is to attract businesses to establish their headquarters or a trading hub in Thailand, thus bringing more tax revenues, skilled jobs and know-how to the Land of Smiles.

Continue Reading

Taxation

India moves forward on taxation of indirect transfer

By Ashish Bairagra, PeriGrow Consulting

Since 2012, India has been levying tax on transactions which involve transfer of shares or interest in a foreign entity, if it derives its value substantially from assets located in India (the Vodafone controversy). However, there was ambiguity about the term substantially.

Continue Reading

Taxation

Changing tax conditions for foreign investors in Mexico

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

In order to make its tax terms more attractive to foreign investors, Mexico has altered its adjustment mechanism (similar to the windfall profits tax in other countries) for oil exploration bidders, which will occur should oil prices rise beyond certain levels or if hydrocarbon discoveries turn out to be greater than anticipated. As a result,
a pre-tax profit margin of 20% (up from 15%) has been set before that adjustment mechanism kicks in.

Continue Reading

Taxation

Polish Ministry of Finance clarifies CFC

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

On 1 January 2015, Poland introduced the Controlled Foreign Corporations (CFC) regime. Clarifications to the CFC were recently published by the Ministry of Finance (MF). Among  others, the CFC regime is applicable if the following conditions are met (cumulatively):

Continue Reading

Taxation

Overseas property owners in the UK: The honeymoon is over!

By Alan Rajah, Lawrence Grant, Chartered Accountants

The UK's unique exemption from Capital Gains Tax (CGT) for non-UK residents has been reformed with the government's realisation that tax should be paid on gains arising from the sale of UK residential properties. Currently, most foreign property owners in the UK are not subject to CGT and this article
outlines the changes to the UK's CGT regime for non-residents which will come into effect from 6 April 2015.

Continue Reading

Taxation

Mexico’s tax reforms to date and what to expect next

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

President Peña Nieto’s controversial “sugar tax” was brought into force a year ago, targeting high calorie foods to the tune of 8% of their value. While the jury is still out as to whether it has had the desired effect on the population and the various burdens, what has become an issue of far greater significance is the success or otherwise of the more substantial reform package to which the sugar tax belonged.

Continue Reading

Taxation

South African incentives for headquarters in Africa

By Graeme Saggers, Nolands SA

A company that is tax resident in South Africa has the opportunity to benefit from a range of tax incentives that are available to headquarter companies (HQCs). The purpose of this regime is to minimise the tax incidence investment in Africa. The following incentives are available to HQCs and generally apply to transactions between an HQC and a foreign company in which they hold at least a 10% share. 

Continue Reading

GGI Logo 70x50px

GGI Geneva Group
International AG

Schaffhauserstrasse 550
P.O. Box 286
8052 Zurich
Switzerland

Contact

T: +41 44 2561818
F: +41 44 2561811
This email address is being protected from spambots. You need JavaScript enabled to view it.
www.ggi.com