International Trade Tax General Business

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Cyprus and Iran sign Double Tax Treaty

On 4 August 2015, the governments of Cyprus and Iran signed an agreement for the avoidance of double taxation (the Treaty). With the lifting of international sanctions against Iran, Cyprus is now uniquely positioned to act as...more

Use of Estonia in U.S. International Tax Planning

According to recent estimates, Estonia, which is situated halfway between Stockholm and St. Petersburg, currently has more than 350 start-up technology companies – one for every 3,700 citizens – and the government expects...more

"Treasury Releases Notice Addressing Transactions Involving Related-Party Partnerships"

On August 6, 2015, the Department of the Treasury issued Notice 2015-54 (the Notice) announcing its intent to issue new regulations addressing transactions involving partnerships formed by related parties. According to the...more

International Tax Alert (US): Offshore e-Commerce Service Providers: Changes to Japan's Consumption Tax Act are Going into Effect

Offshore e-commerce service providers should make themselves aware of changes to Japanese law that affect their operations. Pursuant to a recent amendment of the Consumption Tax Act, a new Registration of Foreign...more

Successful Strategies for Doing Business in Asia: Indonesia (Updated)

1. WHAT ROLE WILL THE GOVERNMENT OF INDONESIA PLAY IN APPROVING AND REGULATING FOREIGN DIRECT INVESTMENT? The existing Indonesian Investment Act is Law No. 25 of 2007, passed by the Indonesian House of Representatives...more

UK Supreme Court Forces HMRC to Rethink its Tax Treatment of Delaware LLCs

Supreme Court rules in favour of taxpayer in landmark case regarding UK tax treatment of Delaware LLCs. On 1 July 2015, the UK Supreme Court handed down a long-awaited ruling in the case of Anson v Commissioners for Her...more

Making Foreign Investment In Thailand

The Kingdom of Thailand is a sovereign country (514,000 sq. km) located in South-East Asia bordered by Burma in the north and west; Laos to the north and east; Cambodia to the east; and Malaysia to the south. It has...more

MoFo Tax Talk - Volume 8, Issue 2

IRS Releases Notices Designating Certain “Basket Contracts” As Listed Transactions And Others As Reportable Transactions Of Interest - On Wednesday, July 8, the IRS released two notices addressing “basket contracts,”...more

New Restrictions on Transferring Appreciated Property to Partnerships With Related Foreign Partners

The IRS issued Notice 2015-54 stating that it plans to issue regulations under Section 721(c) to ensure that U.S. taxpayers do not use partnerships to shift built-in gains to non-U.S. affiliates. In 1997 Congress authorized...more

Country-by-Country Reporting in the EU: Spain Adopts Regulations and the European Parliament Votes for Public Disclosure

On 11 July 2015 a new Corporate Income Tax Regulation (CITR) was approved in Spain, introducing, amongst other things, amendments to the Spanish transfer pricing reporting requirements. The new requirements largely reflect...more

WTO Members Agree to Cut Tariffs on IT Products

On Friday, July 24, 2015, the World Trade Organization (WTO) announced that more than 50 of its member countries had agreed to cut tariffs on hundreds of information technology (IT) products, including semiconductors, MRI...more

Australian Taxation Office issues new Practice Statement on Advance Pricing Arrangements

The tax and in particular the transfer pricing arrangements of multinationals is currently under the spotlight both internationally, through the OECD/G20 BEPS project, and domestically in Australia, by way of the Senate...more

Polish CIT exemption applies also to special Cypriot funds managed by a corporate body

In a recent Polish Supreme Administrative Court’s award it was confirmed that a non-UCITS fund should benefit from the Polish CIT exemption for investment funds, even if their corporate manager is contracted. The award...more

Ukraine: New Rules for Advance Pricing Agreements Adopted

On 25 July 2015 the Cabinet of Ministers of Ukraine published an order on the conclusion of advance pricing agreements ("APA") in respect of controlled transactions for transfer pricing purposes* ("the APA Order"). The APA...more

Eliminating Tariffs on Information Technology (IT) Products: Expanded WTO List on the Horizon

On July 24, 2015 the World Trade Organization (WTO) announced that negotiators had agreed on a list of products and draft declaration to expand the product scope of the 1996 Information Technology Agreement (ITA). The...more

Global Tax News - July 2015

EUROPEAN UNION RE-LAUNCHES FORMULARY APPORTIONMENT: KEY POINTS ABOUT THE CCCTB The European Commission has recently released a Communication to the EU Parliament calling for a re-launch of its proposal from 2011...more

The UK Summer Budget - Private Equity and Investment Management

The Chancellor of the Exchequer’s Summer Budget on 8th July introduced a series of unexpected tax changes affecting the private equity and investment management industry along with the promise of further changes to come....more

Guide To Doing Business in New Zealand: Taxation (Updated)

TAXATION - It is not possible to give a complete outline of the scope of the taxation system in this guide. A brief outline of the basic taxation principles and some of the major forms of taxation are discussed below....more

UK Summer Budget 2015: Osborne's 'Big Summer Budget' – the key measures impacting business

The first fully Conservative Budget for 18 years, following the end of the Coalition as a result of the May general election, was anticipated to be a 'Big Budget' but in truth it was a mixed bag: the game changers are the...more

UK Summer Budget 2015

On Wednesday, 8 July 2015, George Osborne delivered the UK Summer Budget. The first Budget of the new Conservative government (and the second Budget of 2015), the Summer Budget is wide-ranging in scope and potentially...more

India: Recent Developments Regarding Minimum Alternate Tax

Over the past few months, several foreign portfolio investors registered in India have received notices from the Indian tax authorities demanding payment of Minimum Alternate Tax in respect of transactions which took place...more

Commission Payments to IC-DISC Recharacterized as Non-Deductible Dividends

In Summa Holdings, Inc. v. Commissioner, T.C. Memo 2015-119, the Tax Court recharacterized an exporter’s deductible commission payments made to an IC-DISC as non-deductible dividend payments to the exporter’s shareholders...more

Environmental Protection Tax Law of the People’s Republic of China (2015 Draft)

June 10, 2015 marked the day that the Chinese government released a new draft law for public comment. China’s increased awareness of the long lasting effects of pollution on the country’s land, water, and people is reflected...more

CBSA Updates its 2015 Trade Verification/Audit Targets

This month, the Canada Border Services Agency (CBSA) updated its customs compliance verification priorities for 2015. Trade program verifications of tariff classification, customs valuation and origin are not limited to...more

Latest Developments in the Ongoing UPS Class Action

A recent decision of the Divisional Court, in which Bennett Jones and its co-counsel acted for the class, held that whether brokerage fees charged by UPS to customers receiving deliveries in Canada are unsolicited is an...more

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