The proposed Danish tax amnesty
April 19, 2012 in European Tax Service
Daniel Reece, Managing Director Equinor A/S Denmark has recently implemented a tax amnesty in order to increase tax revenue and obtain information from recalcitrant taxpayers. The following article discusses the issues involved. I. Introduction In late 2010, all parties in the Danish Parliament, with the exception of the Social Democrats, agreed to introduce a tax [...]
Russia: Guidance clarifies VAT filing requirements for business partnerships
April 18, 2012 in Indirect Taxes
Rick Mitchell, Bloomberg BNA MOSCOW — Russian regulators released guidance April 12 on how business partnerships should file their value-added tax returns, noting that managing members of business partnerships as well as managing parties in concessions agreements must file tax reports on behalf of the partnerships. In the joint guidance, the Russian Finance Ministry and [...]
Switzerland, Austria Conclude Agreement On Taxation of Swiss Bank Account Income
April 16, 2012 in International Tax Monitor
Daniel Pruzin GENEVA — Switzerland announced April 13 it has concluded an agreement with Austria on the taxation of income from Swiss bank accounts, marking another forward step in the country’s efforts to preserve its embattled tradition of banking secrecy. Swiss President Eveline Widmer-Schlumpf and Austria’s Federal Minister of Finance, Maria Fekter, signed the withholding [...]
Brazil: New Economic Stimulus Package Offers Tax Breaks for 15 Business Sectors
April 5, 2012 in International Tax Monitor
Ed Taylor RIO DE JANEIRO — The Brazilian government April 3 announced a package of fiscal and financial measures to assist the nation’s industry, which has been losing ground to imports. Officials expressed hope that the combination of tax incentives and subsidized loans will guarantee economic growth of 4.5 percent this year. In the fiscal [...]
Spain: Austerity Plan Offers Controversial Tax Amnesty, Modifies Corporate Taxes
April 3, 2012 in International Tax Monitor
Brett Allan King MADRID — Following its presentation of the most austere budget proposal in Spain’s democratic history, the Spanish government April 1 put into force a controversial decree-law with a tax amnesty and other measures aimed at raising tax revenue from companies and investors. Royal Decree-Law 12/2012, which the Council of Ministers approved March [...]
India: 2012 budget holds unpleasant surprises for non-residents
April 2, 2012 in Asia-Pacific Focus
N C Hegde and Vishal Palwe, Deloitte, Haskins & Sells, Mumbai Eagerly awaited by resident and non-resident taxpayers alike, India’s budget for 2012 (Finance Bill 2012) announced on March 16, 2012 contains a number of significant – and far-reaching – direct tax measures that will have negative implications for non-residents. One of the measures provides [...]
Russia’s National Strategy Seeks Reduction in Tax Rates for Oil, Gas Sector
March 28, 2012 in International Tax Monitor
ST. PETERSBURG, Russia — The Russian government wants to reduce tax rates on the oil and gas sector to better insulate the country from fluctuations in the global oil market as part of a wide-ranging strategy that sets out a new model for economic and social development for Russia through 2020. The plan is expected [...]
Singapore: Budget 2012 — analysis of major tax changes
March 26, 2012 in Asia-Pacific Focus
Sunit Chhabra, Lim Pek Bur, Nand Singh Gandhi and Tang Siau Yan, Allen & Gledhill LLP, Singapore The Minister for Finance, Mr Tharman Shanmugaratnam, delivered the Budget Statement for Financial Year 2012 (“Budget 2012”) on February 17, 2012. The significant tax changes announced in Budget 2012 are highlighted below. I. Enhancements to Productivity and Innovation [...]
Foreign Principal Services Structures: Navigating the Subpart F Rules
March 23, 2012 in Tax Management International Journal
Lowell D. Yoder, Esq. McDermott Will & Emery LLP Chicago, Illinois Businesses providing services are a major sector of our current economy, and many U.S.-based service providers operate on a global basis. Conducting operations outside the United States through principal structures can provide commercial and tax efficiencies. Careful planning, however, is required to minimize current [...]
France: Amended 2012 budget law approved
March 21, 2012 in Tax Planning International Review and Forum
Ambroise Bricet, Patrick Fumenier & Marie-Pierre Hoo Taj, France I. Corporate Tax A. Taxes on financial transactions As announced in February 2012, France intends to unilaterally impose a financial transactions tax. The government has approved three separate taxes, which will apply as from 1 August 2012: 1. A tax of 0.1 percent on the acquisition [...]