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.

Continue Reading

Taxation

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).

Continue Reading

Taxation

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).

Continue Reading

Taxation

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.

Continue Reading

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.

Continue Reading

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.

Continue Reading

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.

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