International Tax News - March 2014

by DLA Piper
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DLA Piper - International Tax News

NETHERLANDS: TAX TREATMENT OF HYBRID FINANCE INSTRUMENTS IN THE WAKE OF TWO LANDMARK CASES

By Roderik Bouwman and Gabriël van Gelder

The Dutch Supreme Court has given its judgment in two landmark cases regarding the classification of hybrid finance instruments.

The question in both cases was whether shares can be requalified as a debt instrument for tax purposes.

As in many jurisdictions, the distinction between equity and debt for the purposes of taxation is of great importance. The Dutch Supreme Court’s final decision in both cases stated that the classification of shares under Dutch civil law is decisive.

Find out more.


SINGAPORE AIMS TO PROMOTE BUSINESS BY ENHANCING CORPORATE TAX INCENTIVES: KEY POINTS IN ONE CHART

By Maureen Doran

Singapore’s government, faced with an environment of rising business costs due to near full employment and escalating rents, has proposed enhanced incentives intended to support business transformation and upgrading, in particular for small to medium sized enterprises.

Our chart conveniently sets out some of the key corporate incentive enhancements Singapore intends to provide. See it here.


UK BUDGET 2014: CORPORATE, FINANCE AND REAL ESTATE TAX HIGHLIGHTS

The UK Chancellor of the Exchequer has announced key items of interest in the 2014 Budget relating to businesses, corporate and finance taxation and real estate taxation.

Find out more.


AUSTRALIA: GST AND BITCOIN – POTENTIAL PITFALLS

By Matthews Cridland

Australian GST registered businesses looking at accepting bitcoin payments should be cautious about a possible double GST liability.

While monetary payments and foreign exchange transactions are generally exempt from GST, the issue with bitcoins is that they may not qualify as “money” or “currency of a foreign country” for GST exemption purposes. Bitcoins are a virtual currency and thus are not the currency of any country.

For companies doing business in Australia, we examine the GST implications of bitcoin currency and let you know some considerations if bitcoin payments are in your future.


MOVE TOWARDS A CHINESE FATCA?

By Joyce He, Doris Ho and Stephanie Van Der Schaft

China’s new Circular 642 expands the group of persons subject to tax reporting requirements, as well as the reportable events. It is already in effect.

Some observers are comparing its reach to that of the US Foreign Account Tax Compliance Act – FATCA.

Find out more about these reporting obligations, which, notably, affect cross-border transactions and foreign assets.


SPAIN AMENDS TAX TREATMENT OF DEBT RESTRUCTURING

By Carlos Rodriguez

Spain has substantially reformed its Insolvency Law. The reform includes a new approach to the tax treatment of debt restructuring.

Among the changes emanating from this change: both the Corporate Income Tax Law and stamp duty regulations have been modified.

Find out more.

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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