05/31/2021
This decision was based on an assessment by the Commission of the aforementioned transactions under the criteria for the relevant anti-abuse provision, as laid down in case law.
05/30/2021
The principles were drawn from public international law, the design of the MLI, and the MLI’s drafting history.
05/28/2021
The Italian tax authorities were asked by an Italian film maker (company) whether the remuneration paid to a Spanish resident actress for her performances carried out in Italy were subject to Italian income tax (through the standard 30% final withholding
05/27/2021
The charge is a rise from the stamp duty normally charged on residential property in Ireland, which is 1% of a property value up to €1 million, and 2% on the balance of any higher value.
05/24/2021
The government has set itself the target of raising total investment in research and development (R&D) to 2.4% of UK GDP by 2027.
05/17/2021
The first proposed test is a 183 day test. A taxpayer will be a tax resident of Australia if they spend 183 days or more in Australia in an income year.
05/12/2021
Taxpayers in this category will fall into two groups.
05/10/2021
A recent High Court judgment considered the question of costs awards in these cases stated.
05/07/2021
In the past decade many governments have made a lot of progress in getting archetypal havens to start sharing information on the owners of offshore wealth.
05/06/2021
Part of "Tax Mind": A collection of thought provoking content for tax professionals.
05/04/2021
The proposed concession will address general partners and fund/investment managers’ concerns on the tax exposure relating to their performance fee, or commonly known as “carried interest”.
05/03/2021
The so called “new taxing right” would be an overlay to existing nexus and profit allocation rules.
04/30/2021
In line with prior downturns, over the last number of months we have seen a significant rise in the formation of 'tax blocker' subsidiaries for existing US CLO issuers with exposure to affected assets.
04/30/2021
The update advises that the CRS reporting functionality in the DITC portal has been re-enabled
04/27/2021
Therefore, users are to be taken into account as important assets for enterprises, capable of driving and changing the taxation approach of various transactions.
04/26/2021
It was originally envisaged that the consideration for the sale would be a mixture of cash and ordinary shares issued by the purchaser.
04/26/2021
A long-running dispute with Germany is fading now that both countries and others automatically exchange data about bank accounts.
04/23/2021
The element of the payment which is made on behalf of the player will be treated as taxable income of the player as a ‘benefit in kind’.
04/23/2021
The information to be exchanged relates to the identity, activities, and ownership chain of entities that are noncompliant with substance requirements or that engage in “high-risk” activities, such as activities relating to intellectual proper
04/21/2021
The offshore financial interests of millions of Britons have been handed to HMRC since 2018