News & Analysis as of

Value-Added Tax

Waiver of contractual right

by Hogan Lovells on

In a binding private ruling published on 2 May 2017, SARS was requested to confirm the income tax, donations tax, capital gains tax and value-added tax consequences of the proposed waiver of a right to receive an annual...more

Prepared for the Border Adjustment Tax? A U.S. and Global Perspective

by K&L Gates LLP on

K&L Gates' Global Tax Group has been monitoring the potential impact of the Border Adjustment Tax (BAT) across a number of jurisdictions. In our 14 February 2017 update, we commented that issues regarding the legality of...more

A Guide to UK Tax on Commercial Real Estate: Non-Residents

by King & Spalding on

1. Introduction - This client alert provides a summary of key UK tax considerations when a nonresident invests into UK commercial real estate. There are a number of holding structures for investment into UK real estate...more

Tax and non-executive directors

by Hogan Lovells on

In the 2016 Budget Review, the Minister of Finance stated that in terms of the Income Tax Act 58 of 1962 (the ITA) and the Value-Added Tax Act 89 of 1991 (the VAT Act), a non-executive director’s (NED) fees may be subject to...more

Connected persons

by Hogan Lovells on

The South African Revenue Service has issued a revised interpretation note relating to "connected persons" for comment by 31 March 2017....more

House Proposal for Border Adjustability and Relevant WTO Rules

by Hogan Lovells on

On June 24, 2016, on behalf of the House Republican Caucus, House Speaker Paul Ryan, R -Wis., and House Ways and Means Chairman Kevin Brady, R -Tx., proposed sweeping reforms of the U .S. income and corporate taxes. The...more

Tax Implications For Real Property Leasing

by Morgan Lewis on

Reforms to China’s value-added tax raise issues that landlords should consider when designing leasing structures and negotiating rental terms. On May 1, 2016, China’s value-added tax (VAT) replaced the business tax in...more

Focus on Tax Strategies & Developments - August 2016

by McDermott Will & Emery on

Brexit: The Consequences for International Tax Planning - Just over a month has now passed since the referendum in which the United Kingdom voted narrowly to leave the European Union: an event which some have...more

Doing Business in India? Time to Catch Up on GST Implications!

The introduction of a Goods and Services Tax “GST” in India is quickly approaching and will have an impact on all global businesses. Our friends at Khaitan & Co., one of the oldest and largest Indian law firms, recently put...more

Florida Supreme Court: Origin Sourcing for Sales Tax is Constitutional

by Reed Smith on

The Florida Supreme Court upheld the imposition of a sales tax obligation on an in-state florist for all of its worldwide sales regardless of delivery destination. This “origin sourcing” method of determining transactions...more

United States Challenges Chinese Tax Exemptions for Aircraft at the WTO

by King & Spalding on

On December 8, the United States launched a dispute (DS501) at the World Trade Organization (WTO) regarding tax exemptions on certain Chinese-produced aircraft. The United States has requested consultations with China, which...more

ECJ rules bitcoin exchange is VAT exempt

by Dentons on

In the case of Skatteverket v. Hedqvist, the ECJ ruled that the exchange of traditional currency for bitcoin virtual currency and vice versa constitutes a VAT exempt supply of services under the VAT Directive. The ECJ ruled...more

European Court Gives Bitcoin a Tax-Free Boost

In an important ruling for digital currency service providers, EU’s top court, the Court of Justice of the European Union (CJEU), ruled that transactions to exchange a traditional currency for bitcoin virtual currency, or...more

Virtual Currencies: International Actions and Regulations

by Perkins Coie on

This chart is provided by Perkins Coie LLP’s Decentralized Virtual Currency industry practice group for informational purposes only and is not legal advice. This information is not intended to create, and receipt of it does...more

The Free Port Vladivostok Area

by K&L Gates LLP on

On July 13, 2015, President Putin signed the Federal Law On the Free Port of Vladivostok, as well as two other laws introducing revisions to the current laws required to implement the Law On the Free Port of Vladivostok - the...more

Tax Measures in the UK 2015 Summer Budget

by Morgan Lewis on

The new tax announcements are designed to improve productivity and correct imbalances in the tax system. On 8 July, UK Chancellor of the Exchequer George Osborne made a number of announcements relating to the tax system...more

Bank Julius Baer Customer Implicated in Alleged Tax Fraud

by BakerHostetler on

Reuters is reporting that Bank Julius Baer is cooperating with French authorities in their criminal investigation into an alleged value-added-tax (“VAT”) fraud in the EU Emissions Trading System. ...more

VAT Alert: Cross-Border Supplies Of Services Made To VAT Grouped Branches: Skandia America Corp. (USA), filial Sverige (C-7/13)

by DLA Piper on

For VAT purposes, a supply of services from the headquarters of a company to its branch is generally not subject to VAT. This is well-established, and was confirmed in the Court of Justice of the European Union (the "Court of...more

Skandia: Intra-Company Supplies Treated as Taxable Transactions for VAT Purposes by the Court of Justice of the European Union

On 17 September 2104, the Court of Justice of the European Union (the “CJEU”) gave its preliminary ruling in the case of Skandia America Corporation USA, Sweden Branch v Skatterverket (C-7/13) (“Skandia”). The decision of...more

Recent Change In Consumption Tax In Japan

by DLA Piper on

The OECD Global Forum on VAT held meetings in Tokyo on 17–18 April 2014. These meetings follow the Global Forum’s first meeting in Paris in November 2012. The meetings in Tokyo were part of a series of events commemorating...more

£1 Billion At Stake - Taxpayer wins compound interest on overpaid VAT

by DLA Piper on

The High Court (Henderson J) handed down its decision on 28 March 2014 awarding the mail order and retail company, Littlewoods Retail Limited, compound interest on sums of overpaid VAT that had originally been reimbursed to...more

Update: EU VAT on E-Commerce

by K&L Gates LLP on

There are a great variety of electronically provided services (“e-services”) and the respective market is rapidly growing. The general definition is that e-services are services which are delivered over the Internet or an...more

Web tax into force?

by DLA Piper on

The now “famous” web tax (or Google tax) on the purchase of on-line ads and sponsored links on search engines might come into force on the 1st of March 2014 having an impact on the Internet liability regime, unless the...more

European CLO 2.0 Issuer Jurisdiction Quick Reference Guide

New issuance of collateralised loan obligations (“CLOs”) rose last year to its highest level since the credit crunch. 2013 saw U.S. CLO issuance rise to about US$81 billion, from US$54 billion the year before while European...more

International Tax News - January 2014

by DLA Piper on

WHEN THE PARTIES WANT AN AGREEMENT TO DISAPPEAR: THE US TAX RESCISSION DOCTRINE - The old saw about the best-laid plans of mice and men also goes for international tax planning and transactions with significant tax...more

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