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):
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.
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.
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.
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.
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.
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.
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.
By Mark Pattimore, Heritage Corporate Services Limited
Britain is pressing ahead with plans to have a publicly-accessible, central register of the individuals who ultimately own, and control, UK companies. Will this move to transparency increase trust in UK business as the government hopes or have investors running for cover?
By Carina Langegger, Prodinger & Partner
The question that frequently arises when multi-national corporate groups work on projects across several borders is: Which country has the right of taxation?