The document summarizes new Russian tax legislation that aims to crack down on offshore tax avoidance structures. Key points include: 1) Expanding controlled foreign company (CFC) rules to include trusts and funds; 2) Defining beneficial ownership to determine tax treaty eligibility; 3) Allowing tax residence to be determined by a company's place of management; 4) Taxing real estate transactions via companies that derive over 50% of their value from Russian real estate; 5) Introducing criminal liability for using offshore companies to evade taxes. The changes represent a significant tightening of anti-offshore rules in Russia.
A comprehensive guide of the tax system of Ukraine for foreign investors. Looking to invest in Ukraine? Here's what you have to know about the tax code of Ukraine.
A comprehensive guide of the tax system of Ukraine for foreign investors. Looking to invest in Ukraine? Here's what you have to know about the tax code of Ukraine.
Legal aspects of doing business in the netherlands - 2014Loyens & Loeff
This book was written for investors and their advisors, in order to provide them with a basic understanding of the main areas of Dutch business law. It also gives sufficient background to facilitate communications with Dutch legal counsel.
FOURTH ANTI MONEY LAUNDERING DIRECTIVE (EU) 2015/849’’Eurofast
4th AML Directive enacted on 25.06.2015
Key changes:
1. Beneficial Ownership
2. Coverage of the gambling sector and tax crimes
3. Definition of Politically Exposed Persons (PEPs)
4. The risk based approach
5. Cash payments
6. Sanctions
7. Third country equivalence
E. rumak, p. sitarek, polish leniency programmeMichal
This paper is devoted to the Polish leniency programme, including the conditions
of obtaining lenient treatment and the applicable procedure. The type, scope
and form of information that must be submitted are commented on as well as
the marker system and summary applications. The intersection of the leniency
scheme with private enforcement of antitrust rules is discussed in detail. Special
attention is devoted to the possible ways in which private antitrust plaintiffs might
access information submitted to the UOKiK by leniency applicants. Thoroughly
analysed are the rules regulating the possibility of obtaining relevant documents
from the UOKiK and from the defendant in the course of civil proceedings as well as the status of the administrative decision in subsequent civil litigation. The paper
covers also the scope of the leniency recipient’s civil liability and touches upon
the possible ways in which it could be limited to enhance the effectiveness of the
leniency scheme. Some suggestions de lege ferenda are also provided concerning
the means of increasing this effectiveness without prejudice to the private parties’
right to compensation.
All companies conducting business abroad should be concerned about compliance with
the Foreign Corrupt Practices Act (FCPA or the Act). Companies in certain industries
— like the aerospace and defense industry—due to the heavily regulated nature of the
industry and the level of interaction with foreign governments, are even more vulnerable
to FCPA liability than others.
A look at intra-group loans and safe harbour rules in CyprusChristos Theophilou
Christos Theophilou and Demis Ioannou of Taxatelier present a case study of how the Cypriot tax authorities use safe harbour rules in determining arm’s-length interest rates. The article appears in International Tax Review, published by Euromoney PLC.
Legal aspects of doing business in the netherlands - 2014Loyens & Loeff
This book was written for investors and their advisors, in order to provide them with a basic understanding of the main areas of Dutch business law. It also gives sufficient background to facilitate communications with Dutch legal counsel.
FOURTH ANTI MONEY LAUNDERING DIRECTIVE (EU) 2015/849’’Eurofast
4th AML Directive enacted on 25.06.2015
Key changes:
1. Beneficial Ownership
2. Coverage of the gambling sector and tax crimes
3. Definition of Politically Exposed Persons (PEPs)
4. The risk based approach
5. Cash payments
6. Sanctions
7. Third country equivalence
E. rumak, p. sitarek, polish leniency programmeMichal
This paper is devoted to the Polish leniency programme, including the conditions
of obtaining lenient treatment and the applicable procedure. The type, scope
and form of information that must be submitted are commented on as well as
the marker system and summary applications. The intersection of the leniency
scheme with private enforcement of antitrust rules is discussed in detail. Special
attention is devoted to the possible ways in which private antitrust plaintiffs might
access information submitted to the UOKiK by leniency applicants. Thoroughly
analysed are the rules regulating the possibility of obtaining relevant documents
from the UOKiK and from the defendant in the course of civil proceedings as well as the status of the administrative decision in subsequent civil litigation. The paper
covers also the scope of the leniency recipient’s civil liability and touches upon
the possible ways in which it could be limited to enhance the effectiveness of the
leniency scheme. Some suggestions de lege ferenda are also provided concerning
the means of increasing this effectiveness without prejudice to the private parties’
right to compensation.
All companies conducting business abroad should be concerned about compliance with
the Foreign Corrupt Practices Act (FCPA or the Act). Companies in certain industries
— like the aerospace and defense industry—due to the heavily regulated nature of the
industry and the level of interaction with foreign governments, are even more vulnerable
to FCPA liability than others.
A look at intra-group loans and safe harbour rules in CyprusChristos Theophilou
Christos Theophilou and Demis Ioannou of Taxatelier present a case study of how the Cypriot tax authorities use safe harbour rules in determining arm’s-length interest rates. The article appears in International Tax Review, published by Euromoney PLC.
INSIGHT: Corporate Residence Post-BEPS and Global MobilityChristos Theophilou
Christos Theophilou, of Taxatelier, discusses the various corporate residency criteria that countries are using in order to tax their residents and the interaction of the tax treaties tie-breaker rule for dual-residence companies. The article appears in International Tax News, published by Bloomberg BNA.
A lot has happened to Cyprus over the past 12 to 18 months as the country found itself caught up in the conflagration of the Eurozone debt and banking crisis. As a result, some taxes have been raised on both individuals and companies, but, on the whole, Cyprus remains an attractive jurisdiction for holding companies.
INSIGHT: Treaty Shopping—Is the New Principal Purpose Test a Game Changer? (P...Christos Theophilou
Is the new Principal Purpose Test a game-changer for treaty shopping in relation to holding, financing and royalty structures? The article was published in Bloomberg BNA at International Tax News.
201502 accenture automatic exchange of information regime an emerging compl...Francisco Calzado
publicación acerca de la norma internacional sobre el intercambio automático de información, elaborada por la OCDE junto con el G20 y la colaboración de la Unión Europea.
Este informe pone de manifiesto los nuevos retos en materia regulatoria a los que se enfrentan las entidades financieras tras la adopción de la norma, con especial foco en el impacto que supondrá el cumplimiento de los requerimientos exigidos por el CRS.
The United Kingdom’ s Diverted Profits Tax and Tax Treaties: An EvaluationRamon Tomazela
This article examines the diverted profits tax
(DPT) introduced by the United Kingdom to
counter aggressive tax planning adopted by
many multinational enterprises so as to transfer
profits from its jurisdiction, and the main
controversies surrounding the compatibility of
the DPT with tax treaties.
News has been published for readers with a business interest in Germany. This newsletter informs about latest changes in tax and legal issues including changes in real estate transfer tax, State aid proceedings against Germany by the EU Commission, clarification regarding certifications performed by foreign notaries, etc.
GAZT VAT guide on Financial Services - EnglishFarhan Osman
This guideline is directed for businesses involved in the Financial Services sector, including commercial banks, insurers, asset financing companies; or any business that provides financial services as part of its overall activities.