International Tax News - December 2014

by DLA Piper
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US: 113TH CONGRESS COMES TO A CLOSE – ON TO TAX REFORM

By Evan Migdail and Bruce Thompson

“There’s definitely a deal to be done.” – President Barack Obama speaking about tax reform at the Business Roundtable on December 3, 2014

As the 113th US Congress draws to a close this week with the expected one-year extension of tax provisions that expired at the end of 2013, the President and key members of his Administration have signaled that tax reform is a high priority and one of a short list of legislative accomplishments that he would like to complete during his final two years in office.

For Republicans, the President’s new enthusiasm for tax reform is a welcome development; many have complained that this Administration has done little to advance reform over the past six years while Congress has invested a great deal of time and energy, especially in the House of Representatives, seeking to forge a consensus to update what is viewed as antiquated tax policy that impedes US global competitiveness.

In fact, while there are differences in details, in general conceptual terms, the President’s broad business tax reform outline and the major proposals that have been discussed on the Hill recently are very similar.

There is general agreement, for example, that the US corporate rate is an impediment to economic growth and should come down significantly, and that the US international tax system is out of date and encourages American companies to shift resources and profits overseas.

Over the past few weeks, the Administration and Congressional tax writers have sent signals to each other indicating other areas in which there is room for compromise.

Find out more about these developments.

SPAIN REFORMS ITS TAX REGIME

By Carlos Rodriguez and Maria Alonso

Spain’s recently published tax reform measure modifies the tax regime for companies, individuals and non-resident taxpayers.

The new regulation will come into force as of 1 January 2015, although there are certain exceptions that will be noted below.

Find out more about the main tax developments introduced in the new regulation.

UK WILL IMPOSE CAPITAL GAINS TAX ON NON-UK RESIDENTS

By Richard Woolich, Neville Wright and Mark Burgess

The UK government aims to go ahead with plans to impose capital gains tax on sales of residential property from April 2015.

The government has published detailed proposals for imposing a CGT charge on non-UK residents who dispose of UK residential property. The new charge will take effect for disposals from April 2015 to gains accruing after that time.

Find out more.

UK: CHANCELLOR OF THE EXCHEQUER’S AUTUMN STATEMENT

By Richard Woolich, Paul Rutherford, Neville Wright, Mark Burgess and David Thompson

The Autumn 2015 statement from the UK Chancellor of the Exchequer addresses a number of key tax developments.

Among them:

The “diverted-profits tax” on multinationals that artificially move profits from the UK to lower-taxed jurisdictions goes into effect April 2015

As part of the government support for the OECD project on base erosion and profit shifting (BEPS), country-by-country reporting for multinationals will be instituted, requiring such companies to provide information to HMRC on their global allocation of profits and taxes and on certain indicators of economic activity by territory

The late paid interest rules (which deny companies tax relief for interest on related-party debt until the interest is paid, rather than when the interest accrues, if it remains unpaid for 12 months) will see changes

The small and medium enterprise R&D tax credit rate will increase to 230 percent

Find out more about these and other developments revealed in the Autumn Statement

DISCLAIMER: Because of the generality of this update, the information provided herein may not be applicable in all situations and should not be acted upon without specific legal advice based on particular situations.

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