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New rules for vat taxation of e-commerce services in Russia

On 3 July 2016 Russian President Vladimir Putin signed Federal Law No. 244-FZ introducing rules for VAT taxation of e-commerce services in Russia (Law)....more

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

ECJ Ruling Opens Door To Withholding Tax Refunds

The European Court of Justice (ECJ), in the case of Brisal, has determined on 13 July 2016 that national law which prohibits a non-resident taxpayer from deducting financing/operating costs from interest withholding tax...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

SC Department of Revenue Issues New Guidance on Application of Use Tax to Foreign and Out-of-State Property Brought into South...

The South Carolina Department of Revenue (“DOR”) has issued new SC Revenue Ruling #16-6, providing use tax information for individuals, businesses, and nonprofits. The ruling supersedes SC Revenue Ruling #08-6 and provides...more

The Administrative Procedure Act - Challenging FBAR Penalties

Over the past 10 years, thousands of U.S. taxpayers with a wide variety of circumstances have been forced to pay extraordinarily high penalties for failure to disclose foreign bank accounts. For years, tax experts said that...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

¡Primera Convicción de FATCA!

El 9 de Mayo del 2016, el Departamento de Justicia (DOJ) anunció su primera convicción usando FATCA. Parece ser el principio de procesos penales por el DOJ contra violaciones aparentes o presuntas de los requisitos de...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

Financial Services Quarterly Report - Second Quarter 2016: The Société de Libre Partenariat: A New French Fund Alternative

The implementation of the AIFM Directive has afforded the French legislature the opportunity to simplify its range of regulated investment vehicles, with the aim of making France’s financial markets more attractive – both to...more

Import of raw materials and components for manufacturing of medical devices exempted from VAT

Federal Law No. 225-FZ on Amendments to Part Two of the Tax Code of the Russian Federation dated 30 June 2016 enters into force on 1 August 2016. According to the law, a VAT exemption is granted on import of raw materials and...more

Canada to Increase Import Quota for EU Cheese, July 2016

Both Canada and the European Union (EU) are now in the process of ratifying and implementing The Canada and European Union Comprehensive Economic and Trade Agreement (CETA). Under the terms of CETA, Canada will open for...more

Brexit Update: What’s Next for the Global Marketplace

In Depth - UK Withdrawal Process - The United Kingdom will continue to be an EU member until procedures are completed for exiting the European Union, which is likely to be a long process. Under EU Treaty rules,...more

President Signs Law Charging VAT on Services Provided via the Internet

On 3 July 2016 the President of the Russian Federation signed Federal Law No. 244-FZ on Amendments to Parts One and Two of the Tax Code of the Russian Federation (the “Law”), which enters into force on 1 January 2017....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

Singapore’s Banking Secrets - Not So Secret Anymore

Since 2008, the U.S. Government has largely focused its enforcement actions against Swiss banks that may have assisted U.S. taxpayers in evading federal taxes. In August 2013, the Department of Justice (“DOJ”) introduced the...more

Proposed QI Agreement Addresses Cascading Withholding on Dividend Equivalents

On July 1, the U.S. Internal Revenue Service issued Notice 2016-42, which proposes changes to the qualified intermediary (QI) agreement to address cascading U.S. withholding tax on dividends and “dividend equivalents”...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

Brexit – The UK and International Tax Consequences

The political, economic and constitutional fallout of the UK’s referendum decision to leave the European Union (Brexit) will continue for some time. In addition to considering some of the possible domestic UK tax implications...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

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