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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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).

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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).

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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.

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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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