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.

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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):

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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.

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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.

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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. 

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Taxation

Pierre Gramegna ended a niche tax exemption

By Prof. Robert Anthony, Anthony  Cie

The fourth amendment to the Tax Treaty between France and Luxembourg, as signed by the Ministers of Finance for the Grand Duchy of Luxembourg Pierre Gramegna and for France Michel Sapin, will further restrict potential tax evasion schemes and abuses by French financial investor centres. After an amendment in 2006 ended the non-taxation of immovable property in France owned by Luxembourg companies, another tax exemption has now been eliminated.

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Taxation

Expo Milano 2015 — tax implications for participants

By Matteo Bedogna, Studio Baldi

From 1 May 2015, Milan will be hosting Expo 2015. In addition to enjoying the numerous interesting themes presented, foreign participants will also have to deal with questions of a tax nature. Both Official Participants (countries and international organisations) or Non-Official Participants (private entities and non-governmental institutions) will be able to conduct non-commercial and commercial institutional activities in their pavilions, including the sale of products, catering and paid performances, for example.

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Taxation

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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Taxation

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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