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China makes major changes to transfer pricing documentation and country-by-country reporting requirements

China’s State Administration of Taxation (SAT) on 13 July released on its website guidance that makes substantial changes that apply to multinationals’ transfer pricing compliance obligations for the 2016 fiscal year....more

UK Government Confirms Introduction of New Cap on Interest Deductibility

The UK Government has recently confirmed that it will be introducing a new cap on interest deductibility. Under the new rule, the ability of groups to obtain tax relief for interest will be limited by reference to a ratio of...more

Development of the practice of charging the person beneficially entitled to income additional tax when income is paid to foreign...

On 11 July 2016 the Commercial Court of Moscow rendered a decision in case No. ?40-442/15-39-2 under the claim of Credit Europe Bank CJSC (the “Bank”). That decision is yet another judgment on the subject of applying the...more

The Financial Report, Volume 5, Number 13

On June 23, just hours after we published our last edition, the United Kingdom voted to exit the European Union. Brexit, as it has come to be known, immediately raised a number of issues of potentially enormous significance...more

The Luxembourg Reserved Alternative Investment Funds Law Has Arrived

The entry into force of AIFMD in Europe has resulted in a double layer of regulation, as we now have regulation and supervision at the level of the product (regulated investment funds) and supervision at the level of the...more

What Does Brexit Mean for UK Tax?

Once the formal procedure under Article 50 of the Lisbon Treaty is initiated by the United Kingdom, the government will negotiate the terms of its exit from the European Union. Whilst we must accept that this is a period of...more

The reverse charge mechanism

DLA Piper's Tax team in Poland and the Association of Importers and Manufacturers of Electrical and Electronic Equipment - ZIPSEE "Digital Poland" have prepared a report on the tax consequences of the reverse charge mechanism...more

Brussels Tax Alert

A. Beneficial tax regime - Law 89/1967 "On the Establishment in Greece of Foreign Commercial and Industrial Companies" was meant to attract foreign investments in Greece, by providing a wide range of benefits regarding...more

Five key elements of the EU ATA Directive compromise

In late June, the Economic and Financial Affairs Council of the European Union (ECOFIN or the Council) achieved political consensus on the content of the EU Anti-Tax-Avoidance Directive (the ATA Directive). In last month's...more

What are the Tax Consequences of BREXIT for U.S. Taxpayers?

Recently, The Harvard Law School Forum on Corporate Governance and Finance published a note titled "The Legal Consequence of Brexit, authored by Simon Witty. We have restated the transactional tax commentary here. We have...more

Tax Newsletter - March / April 2016 (China and Hong Kong)

Welcome to the latest issue of our Tax Newsletter. In this issue, we have covered a number of developments and cases in the PRC and Hong Kong which could impose legal and tax implications to your business. In the PRC, an...more

Hong Kong & Singapore: Awaiting a New DOJ Tax Program for Asian Banks?

As the Department of Justice is wrapping up its prosecution of over a dozen Swiss banks, federal prosecutors and IRS special agents are analyzing a treasure trove of previously undeclared taxpayer account information that...more

Brexit Q&A: Business Implications

On Thursday 23 June 2016, the UK electorate voted to leave the European Union. While this vote was advisory in nature, we expect that ultimately the UK Government and Parliament will respect the outcome and serve notice to...more

Brexit: Keep Calm and Carry On?

Does the United Kingdom’s vote to leave the European Union change the United Kingdom’s attractiveness as a holding company jurisdiction?...more

Brexit: Key Tax Implications for Alternative Investment Funds and Investment Managers

The result of the UK’s referendum of 23 June 2016 was announced today as a victory for ‘Brexit’ - in other words, for the UK to exit the European Union. This decision is expected to have significant ramifications for the...more

Amid the Economic Uncertainties of the Brexit, New Challenges in Corporate Tax Structuring for UK Companies (And Their Parents,...

The June 23, 2016 “leave” Brexit vote has left many in the business and legal communities stunned, and while uncertainties abound, there is no doubt that wading through the economic and administrative complexities of exiting...more

Alert: The Tax Implications of Brexit

There are no immediate tax consequences of the Brexit vote. When the UK leaves the EU (which should not be for a period of at least two years) customs duties and tariffs may change depending on the outcome of...more

BREXIT: The UK Has Chosen To Leave The EU. What Next?

On 23 June 2016, the UK held a referendum in which the British people voted for the UK to leave the European Union. But what does this mean in practical terms? Who will BREXIT affect? Any business or financial...more

Brexit: What are the implications for tax law?

The precise impact of a Brexit on UK tax law is not possible to determine without knowing the terms of the exit negotiated by the UK with the EU and future government decisions. There are various ways the relationship between...more

EU Council Agrees on Final Anti Tax Avoidance Directive

We wrote in February (European Commission Publishes Anti Tax Avoidance Package) about the draft EU Anti Tax Avoidance Directive (“ATAD”). On 21st June 2016, the EU Council agreed on the final text of the ATAD and it will...more

ECOFIN reaches consensus on EU ATA Directive

On June 21, 2016, the ECOFIN Council agreed on the content of the EU Anti-Tax-Avoidance Directive (ATA Directive). In last month’s voting, ECOFIN was unable to reach consensus on the ATA Directive. This week’s...more

Anti Tax Avoidance Directive

On 21 June 2016, the EU Council reached agreement on the EU Anti Tax Avoidance Directive (“ATAD”). The ATAD is expected to be adopted in a forthcoming ECOFIN meeting, possibly on 12 July 2016. The Council had reached...more

Doing business in the Ras Al Khaimah Free Trade Zone

Major benefits of incorporating inside a free trade zone, as opposed to on the UAE’s mainland. However, in brief the companies are entitled to 50 years of zero corporate tax while still being entitled to repatriate the...more

Doing business in the Dubai Airport Freezone

Major benefits of incorporating inside a free trade zone, as opposed to on the UAE’s mainland. However, in brief the companies are entitled to 50 years of zero corporate tax while still being entitled to repatriate the...more

The Panama Papers and Shell Games – Part II

Today I conclude my exploration of some of the issues raised by Ryan Hubbs, a senior manager of fraud investigation and dispute services at Ernst & Young LLP (EY), in the 2014 Fraud Magazine article, entitled “Shell Games”....more

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