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International Trade Tax

Read need-to-know updates, commentary, and analysis on International Trade issues written by leading professionals.

Window on Washington - This Week in the Nation's Capital - Vol. 1, Issue 27

by Clark Hill PLC on

Senate Again Delays Action on Remaining Appropriations Bill: The Senate has yet to schedule any mark-ups for next week for its remaining four appropriations bills (Clark Hill Insight). Senate Reaches Deal on Budget...more

Is a Business Tax Reform Game Plan Beginning to Take Shape?

by McDermott Will & Emery on

Substantial tax reform is underway and the business community is intently awaiting details of this activity with the aim of positioning themselves to maximize opportunities and minimize any costs or risks that reform may...more

UK Tax Round Up - September 2017

by Proskauer Rose LLP on

UK Tax News and Developments - Finance (No 2) Bill 2017 - The second Finance Bill of 2017, known as Finance (No 2) Bill 2017, has now been published. As expected, this contains most of the provisions which were dropped from...more

The Netherlands - Budget 2018 - Dividend withholding tax and non-resident taxation

by Dentons on

On 19 September 2017, the Dutch government released the State’s Budget for the year 2018. The Budget includes a draft bill to expand the dividend withholding tax exemption to tax treaty countries, to introduce a withholding...more

Tax treaty interpretation

by Hogan Lovells on

On 31 August 2017, the Dutch Court of Appeals of 's-Hertogenbosch issued judgment in a case dealing with the application of the most-favoured-nation (MFN) clause contained in the Netherlands/South Africa Double Tax Agreement...more

French Elections Pave Way for Labor, Tax Reforms

In the months following the election of President Emmanuel Macron, who is perceived as pro-business, as well as a parliamentary election in which the new president’s party won the majority, companies and entrepreneurs have...more

New Extra-Territorial UK Corporate Criminal Offence of Failing to Prevent Tax Evasion

by Goodwin on

A new corporate criminal offence of failing to prevent the facilitation of tax evasion takes effect on 30 September 2017. Corporates in both the UK and abroad will incur strict liability if their employees or other associated...more

Draft Legislation Published on UK Partnership Taxation

by Goodwin on

Earlier this year, HM Revenue & Customs published various ideas to ‘clarify’ the tax treatment of partners in partnerships, as part of its response to a consultation on changes to the taxation of UK partnerships. Draft...more

Swiss-Domiciled Company Denied Treaty Benefits For Treaty Shopping

by Fox Rothschild LLP on

Statutory Background- When a foreign corporation receives dividends from U.S. sources, the income is generally subject to tax at 30%. To avoid double taxation and encourage cross-border investments, the U.S. has entered...more

VAT In the UAE - What Your Business Needs to Do

by Bracewell LLP on

The UAE will introduce value added tax (“VAT”) at the rate of 5% from 1 January 2018. The basic principle underpinning the introduction of VAT is to further improve the economic base of the UAE. This is a significant...more

Boletín Mensual de Comercio Internacional - Agosto - Información con énfasis en la Regulación Comercial y de Arbitraje...

by Holland & Knight LLP on

Durante el mes de agosto destacan los siguientes temas: Comercio, Acceso, Prácticas desleales, Propiedad Intelectual, MIPyMEs y Arbitraje de Inversión....more

Energy Newsletter - September 2017

by King & Spalding on

Managing Decommissioning Risks in Asian M&A Transactions - By the end of 2026, approximately 134 producing Concessions and Production Sharing Contracts (each, a “PSC”) will have expired in South Asia. It is expected that 900...more

Information Exchange Under the OECD’s Common Reporting Standard Begins Early in Select Countries

by Alston & Bird on

Modeled after the Foreign Account Tax Compliance Act (FATCA) – the U.S.’s information reporting regime for U.S. holders of foreign accounts – the Organisation for Economic Co-Operation and Development (OECD) approved the...more

UK Enacts New Offences of Corporate Facilitation of Tax Evasion

The Criminal Finances Act 2017 (the Act) will enter into force in the UK on September 30, 2017, creating new corporate criminal offences in respect of the facilitation of tax evasion. Adopting the same approach as the offence...more

New guidance to register as “privileged” domestic or foreign investment fund under German investment taxation law

by Dechert LLP on

Pursuant to the new German investment tax act (GITA) that will take effect of 1 January 2018, domestic and foreign resident investment funds may become subject to German corporate income tax with various German source income...more

FinCEN Extends FBAR Relief To Victims Of Hurricane Irma

by Fox Rothschild LLP on

We previously reported that the Treasury Department’s Financial Crimes Enforcement Network (FinCEN) had granted FBAR filing relief to the victims of Hurricane Harvey. FinCEN announced today that Hurricane Irma victims in...more

WTO Appellate Body Report: US – Conditional Tax Incentives for Large Civil Aircraft

by White & Case LLP on

Decision: The WTO Appellate Body has ruled that certain tax incentives provided by the State of Washington in the aerospace sector are not prohibited import substitution subsidies under the Agreement on Subsidies and...more

Disallowance of Deduction for Interest Paid to Hungarian Affiliate Serves as a Reminder of Department’s Continued Audit Scrutiny...

by Reed Smith on

A case recently resolved at the Appellate Tax Board serves as a reminder that Massachusetts’ auditors continue to aggressively challenge the following intercompany transactions: - Interest deductions for interest paid to...more

Google Ireland Limited does not have permanent establishment in France

The Paris administrative court ruled on July 12th, 2017, that Google Ireland Limited did not have to pay $1.3 billion in back taxes in France for the period 2005-2010. The Irish company Google Ireland Limited sells digital...more

Corporate Tax Residence: Another Chapter

Another Case on Corporate Tax Residence: Why Does It Matter? - Corporate tax residence is an area of enduring enquiry and focus for HM Revenue & Customs (HMRC) in the UK. Development Securities (No.9) vs. HMRC [2017]...more

Protocol Amending the Mexico–Belgium Tax Treaty Published

by Jones Day on

On August 17, 2017, the Protocol amending the Convention for the Avoidance of Double Taxation and the Prevention of Fraud and Fiscal Evasion ("Tax Treaty") between Belgium and Mexico was published in Mexico's Official Journal...more

Morocco publishes new procedures for Advance Pricing Agreements

by DLA Piper on

Morocco has published Ministerial Decree No 2.16.571 outlining the procedure for concluding advance pricing agreements (APAs) with the Moroccan tax authority....more

Se Reglamenta la Exclusión de IVA Para la Creación de Contenidos Digitales

by Holland & Knight LLP on

La Ley 1819 de 2016 (Reforma Tributaria), excluyó del impuesto sobre las ventas (IVA), entre otras los siguientes operaciones: (i) La prestación de servicios de educación virtual para el desarrollo de contenidos digitales, de...more

Funds Talk: September 2017 - Tax Court Declines to Follow Rev. Rul. 91-32

In a recent decision, Grecian Magnesite Mining, Industrial & Shipping Co., SA v. Commissioner, the U.S. Tax Court declined to follow Revenue Ruling 91-32, and held that gain on the sale of an interest in an operating...more

New UAE VAT and Tax Procedures Laws

by K&L Gates LLP on

As of 1 January 2018, value added tax (“VAT”) at the rate of 5% will be applied on a wide range of goods and services in the United Arab Emirates (“UAE”). This follows from the Gulf Cooperation Council’s (“GCC”) entry into a...more

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