Summary of president-elect’s tax proposals

Olivier Ferrari, Patrick Seroin, Gilles Galinier-Warrain, Fidal Newly elected French President François Hollande is presently envisaging tax proposals that could affect both corporate and individual income taxpayers. The following discussion provides a broad overview of the president-elect’s tax plan, based on statements made following the May 6 election. Many of these measures—in particular, those concerning [...]

Exit charges in Asia Pacific: Current trends and approaches in Asia Pacific tax authority enforcement

 Matt Andrew and Michael Nixon Ernst & Young, Singapore It is close to two years since the publication of Chapter IX of the OECD Guidelines, and the interpretation and application of the guidance varies amongst tax authorities across Asia Pacific. The following article seeks to outline the various interpretations of this and other guidanceand current [...]

Australia: Budget 2012–13 measures create uncertainty for foreign investors

Richard Snowden, Cory Hillier and Justin Rossetto, King & Wood and Mallesons, Sydney I. Introduction Australian Treasurer Wayne Swan delivered the Government’s 2012–13 Federal budget on May 8, 2012. The tax measures announced in the budget demonstrate the Australian Government’s significant revenue constraints and its unwillingness to concede reductions in the tax base. The majority [...]

New Brazilian transfer pricing rules: Provisional Measure N 563/2012

Luiz Felipe Centeno Ferraz and Antonio Carlos Fleischmann Mattos Filho, Veiga Filho, Marrey Jr. e Quiroga Advogados, São Paulo, Brazil I. Introduction On April 4, the Brazilian Government published Provisional Measure 563/2012 (“MP 563”) with some significant changes to the Brazilian transfer pricing regulations. While the Brazilian Congress is yet required to convert MP 563 [...]

China’s SAT issues further guidance on the VAT reform pilot program

Sarah Chin and Gao Li Qun, Deloitte, Shanghai I. Introduction On April 5, 2012, the State Administration of Taxation (“SAT”) issued a circular (Bulletin of SAT [2012] No. 13, “Bulletin 13”) to provide detailed implementation guidance for the VAT treatment of zero-rated services — this is a significant development in the VAT reform pilot program [...]

Switzerland, Italy Establish Formal Dialogue To Address Tax Matters, Help Ease Tensions

Dan Pruzin GENEVA — Switzerland and Italy have agreed to establish a formal dialogue and create a steering group to help ease tensions between the two countries over tax matters, the Swiss Federal Department of Finance (FDF) announced May 9. In a statement, the FDF said the dialogue would include a working visit between Swiss [...]

Canada: Important clarification on the application of GST/HST

Mary Anne McMahon, Couzin Taylor LLP, Ottawa I. Introduction In the eagerly awaited decision of Calgary (City) v. the Queen, 2012 SCC 20, the Supreme Court of Canada (SCC) has provided welcome clarification with respect to the application of goods and services tax/harmonized sales tax (GST/HST) to certain grant and subsidy funding, as well as [...]

Tax planning in Central Europe – Inbound investments in Poland

Tomasz Krasowski, Niels Muller , Bartjan Zoetmulder, Salans Warsaw, Loyens & Loeff Amsterdam I. Introduction This article discusses the main tax and certain legal considerations relevant for foreign investors investing in Poland. In particular, this article covers the tax treatment of Polish companies, partnerships and branches, the tax consequences of debt and equity financing, the [...]

EU financial transaction tax gets global scope under European Parliament proposal

BRUSSEL S — The scope of the European Union financial transaction tax should be expanded to cover all securities issued in the EU even if they are sold between two parties based outside the 27 EU member states, according to a proposal that will be voted on in May by the European Parliament. According to [...]