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Global Accountants’ Liability Update – May 2021

Court of Appeal rules in favor of accounting firm in breach of contract claim

US To Tighten Monitoring Of Foreign Crypto Investors In Concerns Over Tax Evasion

The proposal comes as more and more global concern is voiced over the possible tax gap between taxes owed and the taxes that are being paid on time.

Belgium - EU judges oblige Tax Authorities to apply anti-abuse provisions

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.

Opinion on interpretation and implementation of MLI approved

The principles were drawn from public international law, the design of the MLI, and the MLI’s drafting history.

New developments in Italian taxation of image rights

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

Ireland introduces higher stamp duty rate for bulk housing buys

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.

Review of UK R&D tax credits system begins

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.

Tax residency – changes in the wind

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.

Preparing for the Unknown: What a Capital Gains Rate Hike Could Mean

Taxpayers in this category will fall into two groups.

Costs Risk in Appeals from the Irish Tax Appeals Commission

A recent High Court judgment considered the question of costs awards in these cases stated.

The hacker, the tax haven, and what $200 million in offshore deposits can tell us about the fight against illicit wealth

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.

How easy is it for the MRA to lift the corporate veil to recover taxes?

Part of "Tax Mind": A collection of thought provoking content for tax professionals.

Profits tax exemption for private equity funds in Hong Kong

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”.

Taxing the digitalized economy

The so called “new taxing right” would be an overlay to existing nexus and profit allocation rules.

Tax Blockers and US CLOS: Best Practice for Restructuring Distressed Assets

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.

Cayman Islands: Updates regarding DITC portal and CRS and FATCA compliance

The update advises that the CRS reporting functionality in the DITC portal has been re-enabled

Users as digital assets: highlights from a tax perspective

Therefore, users are to be taken into account as important assets for enterprises, capable of driving and changing the taxation approach of various transactions.

Tax avoidance not a main purpose of transaction, says UK tribunal

It was originally envisaged that the consideration for the sale would be a mixture of cash and ordinary shares issued by the purchaser.

Swiss bank pays up to settle German tax evasion probe

A long-running dispute with Germany is fading now that both countries and others automatically exchange data about bank accounts.

UK Footballers and their agents face increased tax bills as HMRC clamp down on perceived tax loophole

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’.