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Corporate tax

November 2018  |  SPECIAL REPORT: CORPORATE TAX

Financier Worldwide Magazine

November 2018 Issue


The corporate tax arena has seen a number of significant developments in numerous jurisdictions across the globe over the past 12 months. Chief among these were the tax reforms signed into law by president Trump on 22 December 2017 – reform legislation that lowers the statutory tax rates on corporations and provides a special deduction for many pass-through entities, while also moving the US toward a participation exemption-style system for taxing foreign-source income of domestic multinational corporations. Additional developments include the Finance Bill 2017-2019 enacted in the UK, which includes new loss relief rules, and changes to substantial shareholding exemption and interest deductibility rules. Elsewhere, the French Finance Bill 2018 introduces a progressive reduction in the corporate tax rate and aligns transfer pricing documentation requirements with the Organisation for Economic Co-operation and Development’s (OECD) recommendations under the Base Erosion and Profit Shifting (BEPS) initiative. These are just some examples of tax reforms which are ongoing around the world – all of which places multinationals in a shifting regulatory landscape.

FORUM: Taxation of intangible assets

FW moderates a discussion on taxation of intangible assets between Emmanuel Llinares, Harlow Higinbotham and Yves Hervé at NERA Economic Consulting.

Criminal liability for violations of FATCA – bankers and others beware

Hochman Salkin Rettig Toscher and Perez, P.C. The Department of Justice (DOJ) has been aggressively targeting offshore tax evasion by US taxpayers since its February 2009 prosecution of Zurich-based UBS AG – the largest Swiss bank – culminated in an agreement to defer prosecution on a charge of...

Modernising international tax rules: from arbitrage to convergence?

Chartered Institute of Taxation Financial leaders will have noticed that the taxation of international companies, particularly those in the digital sector, has hardly been out of the news in the last few years. This article explores how international tax rules have changed in reaction to some of the...

Canada’s tax court provides insight on tax treaties, foreign holdcos and treaty-shopping

Aird & Berlis LLP In a recent case, Alta Energy Luxembourg S.A.R.L v. The Queen, Canada’s tax court ruled favourably on a tax planning structure used by foreign investors pursuing a development in Canadian shale oil. In its decision, the court provided clarity on how investors in...

Tax reform in Argentina: another squeeze of the lemon

Durrieu Canosa The history of Argentina for the past 70 years has been determined by certain constants: an increase in tax, an increase in the power and prerogatives of politicians, and corruption. This is probably a worldwide trend, but in Argentina it seems clearer than anywhere else...

The taxing question of the digital economy

Slaughter and May The current international tax rules were not designed with today’s digital business models in mind. There is a strong global movement to update the rules but with, as yet, no consensus on how best to do this and how quickly it needs to be done. This article examines the problem...

The new Cyprus-United Kingdom double tax agreement

Elias Neocleous & Co LLC On 22 March 2018, Cyprus and the UK signed a new double taxation agreement. Once it has been ratified by both parties, it will replace the current agreement, which dates back to 1974. Most of the main provisions of the new agreement are substantially the same...

Crypto taxation – not all unknown

Hassans International Law Firm The taxation of cryptocurrency transactions and cryptographic token transactions has been a matter of debate within the taxation profession over recent months. The boom in cryptocurrency transactions has meant that what was once an arcane corner of the taxation world, which many would never be asked to consider, has now landed at the forefront...

Developments in Belgian tax

De Langhe Attorneys Following the so-called summer agreement reached by Belgium’s coalition government on 26 July 2017, two major laws were enacted overhauling Belgium’s Corporate Income Tax (CIT) law. By far the most exhaustive one was the law of 25 December 2017...

Impact of the Zinc case on transfer pricing

NovioTax On 27 October 2017, an interesting court decision was published in the field of transfer pricing (TP), which has been named the ‘Zinc case’. The case concerned the centralisation of full-fledged operations into low-risk operations and the question of whether the...

Ukraine progresses with BEPS implementation

CMS Reich-Rohrwig Hainz In 2013, the Organisation for Economic Co-operation and Development (OECD), jointly with G20 countries, initiated the Base Erosion and Profit Shifting (BEPS) project, the main aim of which was to remove tax planning strategies that exploit gaps and mismatches...

Q&A: Managing and resolving cross-border tax disputes

FW moderates a discussion on managing and resolving cross-border tax disputes between Eduardo Gracia at Ashurst LLP, Chris Kinsella at MinterEllison, and Richard Jeens at Slaughter and May.


CONTRIBUTORS

Aird & Berlis LLP

Ashurst LLP

Chartered Institute of Taxation

CMS Reich-Rohrwig Hainz

De Langhe Attorneys

Durrieu Canosa

Elias Neocleous & Co LLC

Hassans International Law Firm

Hochman Salkin Rettig Toscher and Perez, P.C.

MinterEllison

NERA Economic Consulting

NovioTax

Slaughter and May


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