In July, 2014 the minister of finance revealed the draft Tax Code bill.
It addresses many issues identified by the government as leading to (i) income leakages from state budget (ii) ineffective tax collection.
The main modifications concern GAAR, tax rulings and penalty interest scheme.
International Indirect Tax - Global VAT/GST update (June 2018)Alex Baulf
High level slides from Grant Thornton's VAT Club seminar in London held in June 2018.
Topics covered include:
ECJ decision - C-580/16 Hans Bühler - Triangulation
Netherlands - VAT rate change
Russia - VAT rate change
Bahamas - VAT rate change
Angola - New VAT system
Liberia - New VAT system
Costa Rica - New VAT system
Costa Rica - e-invoicing requirements
Hungary - Electronic Invoicing
Italy - Mandatory e-invoicing
Australia - GST on hotel accommodation
Poland - VAT split payments
Spain - First penalties in relation to SII
Greece - SAF-T & E-Invoicing?
Argentina - VAT on digital services
Columbia VAT on digital services
Canada - Quebec: New QST obligations for non-resident suppliers of digital services
USA: Wayfair – the Decision
India - “Happy Birthday GST" - what's next
New Zealand - Low value consignment relief
Malaysia - GST to 0% and transition to SST
United Arab Emirates - Exchange Rates for VAT purposes
Kuwait - VAT postponed until 2021?
GCC - Bahrain, Oman, Qatar VAT implementation latest
Alison Vine, Director at Deloitte, gives practical and concise update on all the latest tax and NIC developments, topical tax issues, planning you will need to be aware of, and the impact of these changes on your clients and your business.
This is an in-house training paper that reviews the highlights of the Income Tax (Country by Country Reporting) Regulations, 2018 released by the Federal Inland Revenue Service.
Opinion expressed herein by the author does not necessarily in anyway represent the Opinion of OECD, ATAF or the Federal Inland Revenue Service (FIRS). The write up is strictly for information purpose, I therefore make no representation as to the accuracy and completeness of the information contained in this publication. I accept no liability for any loss that may arise from the use of this paper.
International Indirect Tax - Global VAT/GST update (June 2018)Alex Baulf
High level slides from Grant Thornton's VAT Club seminar in London held in June 2018.
Topics covered include:
ECJ decision - C-580/16 Hans Bühler - Triangulation
Netherlands - VAT rate change
Russia - VAT rate change
Bahamas - VAT rate change
Angola - New VAT system
Liberia - New VAT system
Costa Rica - New VAT system
Costa Rica - e-invoicing requirements
Hungary - Electronic Invoicing
Italy - Mandatory e-invoicing
Australia - GST on hotel accommodation
Poland - VAT split payments
Spain - First penalties in relation to SII
Greece - SAF-T & E-Invoicing?
Argentina - VAT on digital services
Columbia VAT on digital services
Canada - Quebec: New QST obligations for non-resident suppliers of digital services
USA: Wayfair – the Decision
India - “Happy Birthday GST" - what's next
New Zealand - Low value consignment relief
Malaysia - GST to 0% and transition to SST
United Arab Emirates - Exchange Rates for VAT purposes
Kuwait - VAT postponed until 2021?
GCC - Bahrain, Oman, Qatar VAT implementation latest
Alison Vine, Director at Deloitte, gives practical and concise update on all the latest tax and NIC developments, topical tax issues, planning you will need to be aware of, and the impact of these changes on your clients and your business.
This is an in-house training paper that reviews the highlights of the Income Tax (Country by Country Reporting) Regulations, 2018 released by the Federal Inland Revenue Service.
Opinion expressed herein by the author does not necessarily in anyway represent the Opinion of OECD, ATAF or the Federal Inland Revenue Service (FIRS). The write up is strictly for information purpose, I therefore make no representation as to the accuracy and completeness of the information contained in this publication. I accept no liability for any loss that may arise from the use of this paper.
Presentation delivered during the 13th Annual Meeting of the OECD Network on Fiscal Relations Across Levels of Government, 23-24 November 2017, Paris, France.
Overseas investors continue to look to the UK as
an attractive location to invest. But what are the
key tax implications? Take a look at our guide on structuring your real estate investment in the UK to find out.
My presentation about an European Court of Justice Case about thin capitalization in UK. After analyzing the facts and the fiscal and economic aspects of the operation, the presentation gives the point of view of both the UK Government and the ECJ about the fiscal regime of Thin Cap in UK. The decision of the Court is against UK Thin Cap, since the fiscal regime represents a restriction in the freedom of establishment for non-UK resident parent companies deciding where to establish a subsidiary.
The Federal High Court, Lagos ("FHC") has revoked the decision of the Tax Appeal Tribunal ("TAT") in Gazprom Oil and Gas Nigeria Limited (Gazprom) v. Federal Inland Revenue Service (FIRS) relating to services which Gazprom received from a non-resident company. In Nigeria, the interpretation of destination and source principles of international taxation keeps swinging. Will there ever be an end?
The Portuguese Golden Visa provides free travel within the European Schengen area and the possibility to reside in Portugal. The beneficiaries of this Visa can also ensure that their family members obtain a fully valid residence permit in Portugal. Please take a look at RPBA’s infographic on the types of investment and requirements to obtain a Golden Visa in Portugal.
This is a technical paper presented in an in-house technical session on 30th August, 2018.
The paper reviewed the changes introduced into the Nigerian Transfer Pricing landscape by the Gazetting of the Income Tax (Transfer Pricing) Regulations, 2018.
Opinion expressed herein by the author does not necessarily in anyway represent the Opinion of OECD, ATAF or the Federal Inland Revenue Service (FIRS). The write up is strictly for information purpose, I therefore make no representation as to the accuracy and completeness of the information contained in this publication. I accept no liability for any loss that may arise from the use of this paper.
Presentation delivered during the 13th Annual Meeting of the OECD Network on Fiscal Relations Across Levels of Government, 23-24 November 2017, Paris, France.
Overseas investors continue to look to the UK as
an attractive location to invest. But what are the
key tax implications? Take a look at our guide on structuring your real estate investment in the UK to find out.
My presentation about an European Court of Justice Case about thin capitalization in UK. After analyzing the facts and the fiscal and economic aspects of the operation, the presentation gives the point of view of both the UK Government and the ECJ about the fiscal regime of Thin Cap in UK. The decision of the Court is against UK Thin Cap, since the fiscal regime represents a restriction in the freedom of establishment for non-UK resident parent companies deciding where to establish a subsidiary.
The Federal High Court, Lagos ("FHC") has revoked the decision of the Tax Appeal Tribunal ("TAT") in Gazprom Oil and Gas Nigeria Limited (Gazprom) v. Federal Inland Revenue Service (FIRS) relating to services which Gazprom received from a non-resident company. In Nigeria, the interpretation of destination and source principles of international taxation keeps swinging. Will there ever be an end?
The Portuguese Golden Visa provides free travel within the European Schengen area and the possibility to reside in Portugal. The beneficiaries of this Visa can also ensure that their family members obtain a fully valid residence permit in Portugal. Please take a look at RPBA’s infographic on the types of investment and requirements to obtain a Golden Visa in Portugal.
This is a technical paper presented in an in-house technical session on 30th August, 2018.
The paper reviewed the changes introduced into the Nigerian Transfer Pricing landscape by the Gazetting of the Income Tax (Transfer Pricing) Regulations, 2018.
Opinion expressed herein by the author does not necessarily in anyway represent the Opinion of OECD, ATAF or the Federal Inland Revenue Service (FIRS). The write up is strictly for information purpose, I therefore make no representation as to the accuracy and completeness of the information contained in this publication. I accept no liability for any loss that may arise from the use of this paper.
Conclusiones Grupo 3. Módulo Inicial de Formación de la Red Aragonesa de Proyectos de Promoción de Salud. (Rapps) (http://redaragonesaproyectospromocionsalud.blogspot.com.es/)
Zaragoza 29 de mayo de 2014
It is strange, the designer clutch purse is not a modern fabrication. Modern ladies have been carrying clutch purses on their elegant evenings out for decades.
MEXICO’S 2014 TAX REFORM: A BRIEF REVIEW OF SOME OF ITS MOST RELEVANT ISSUESHogan Lovells BSTL
On 8 September 2013, the Mexican President
submitted to the Mexican Congress a bill
proposing a comprehensive tax reform.
Among other aspects, this bill proposed:
• the enactment of a new Income Tax Law;
• the suppression of the business flat rate tax
(‘IETU’) and tax on cash deposits (‘IDE’);
and
• significant amendments to the Value
Added Tax Law, Federal Tax Law and to
various excise taxes.
A new Decree, which includes changes to the treatment of tax
avoidance and abuse of law, and which should limit the more
enthusiastic challenges by the revenue authorities, has been
approved by the Italian Government.
New laws that affect transfer pricing went into effect in 2018 that will have an effect on 2019 financial reporting. Countries with activities in Denmark, Argentina, Brazil, Saudi Arabia, and Great Britain should be aware of these recent transfer pricing developments.
Grant Thornton China tax bulletin - January 2015Alex Baulf
China Tax Bulletin aims to provide a prompt and high level overview on the latest tax rules released by various authorities, especially those by China SAT and local tax authorities. Implications for your business are also presented for the tax rules
Please see an update prepared by Grant Thornton Italy on the latest legislation regarding VAT approved in Italy, in force as of January 2015, and on provisions in course of enactment.
There are important changes and new rules in relation to:
VAT refunds;
Reverse charge mechanism;
“Split payment” mechanism;
Usual exporters;
Annual VAT return;
VAT warehouse;
Processing on goods;
VAT grouping;
E-invoicing;
Changes in Polish corporate income tax 2020PwC Polska
Changes in Polish corporate income tax 2020. On 23rd of September our experts: Marcin Jaworski and Michał Jagielski summarized biggest corporate income tax challenges and opportunities for 2020.
More info: https://pwc.to/2lkTbOj
As of January 1, 2016 the Dutch Corporate Income Tax Act has been extended with specific regulations regarding Transfer Pricing documentation requirements. These new regulations are applicable for all companies:
being part of an international group/having a permanent establishment;
having a group turnover over euro 50M.
If you meet both requirements the new regulations are applicable as of the financial year starting on or after January 1, 2016.
A brief guide for companies and funds planning to set up investments in Italy, explaining how to get tax benefits from admittance to the the New Tax Compliance Regime
Below is a glimpse of our expectations:
• Consequential amendment needed after the abolition of Dividend Distribution Tax
• Section 54B exemption should be allowed, even if the new agriculture land is purchased before the sale of agriculture land
• Tax deducted in foreign country to be treated as income of assessee
• Clarification required for pass-through of losses incurred by Business trust and Securitisation Trust
• Consequential amendment needed in the Proviso to Section 206C(5) due to omission of Section 203AA
Future of treaty formed holding companies and preferential Harm J. Oortwijn
Past present and future developments in holding and preferential tax regimes - what once was appropriate is now perceived inappropriate... and the perception continues to evolve!
Responsibilities of the office bearers while registering multi-state cooperat...Finlaw Consultancy Pvt Ltd
Introduction-
The process of register multi-state cooperative society in India is governed by the Multi-State Co-operative Societies Act, 2002. This process requires the office bearers to undertake several crucial responsibilities to ensure compliance with legal and regulatory frameworks. The key office bearers typically include the President, Secretary, and Treasurer, along with other elected members of the managing committee. Their responsibilities encompass administrative, legal, and financial duties essential for the successful registration and operation of the society.
WINDING UP of COMPANY, Modes of DissolutionKHURRAMWALI
Winding up, also known as liquidation, refers to the legal and financial process of dissolving a company. It involves ceasing operations, selling assets, settling debts, and ultimately removing the company from the official business registry.
Here's a breakdown of the key aspects of winding up:
Reasons for Winding Up:
Insolvency: This is the most common reason, where the company cannot pay its debts. Creditors may initiate a compulsory winding up to recover their dues.
Voluntary Closure: The owners may decide to close the company due to reasons like reaching business goals, facing losses, or merging with another company.
Deadlock: If shareholders or directors cannot agree on how to run the company, a court may order a winding up.
Types of Winding Up:
Voluntary Winding Up: This is initiated by the company's shareholders through a resolution passed by a majority vote. There are two main types:
Members' Voluntary Winding Up: The company is solvent (has enough assets to pay off its debts) and shareholders will receive any remaining assets after debts are settled.
Creditors' Voluntary Winding Up: The company is insolvent and creditors will be prioritized in receiving payment from the sale of assets.
Compulsory Winding Up: This is initiated by a court order, typically at the request of creditors, government agencies, or even by the company itself if it's insolvent.
Process of Winding Up:
Appointment of Liquidator: A qualified professional is appointed to oversee the winding-up process. They are responsible for selling assets, paying off debts, and distributing any remaining funds.
Cease Trading: The company stops its regular business operations.
Notification of Creditors: Creditors are informed about the winding up and invited to submit their claims.
Sale of Assets: The company's assets are sold to generate cash to pay off creditors.
Payment of Debts: Creditors are paid according to a set order of priority, with secured creditors receiving payment before unsecured creditors.
Distribution to Shareholders: If there are any remaining funds after all debts are settled, they are distributed to shareholders according to their ownership stake.
Dissolution: Once all claims are settled and distributions made, the company is officially dissolved and removed from the business register.
Impact of Winding Up:
Employees: Employees will likely lose their jobs during the winding-up process.
Creditors: Creditors may not recover their debts in full, especially if the company is insolvent.
Shareholders: Shareholders may not receive any payout if the company's debts exceed its assets.
Winding up is a complex legal and financial process that can have significant consequences for all parties involved. It's important to seek professional legal and financial advice when considering winding up a company.
ALL EYES ON RAFAH BUT WHY Explain more.pdf46adnanshahzad
All eyes on Rafah: But why?. The Rafah border crossing, a crucial point between Egypt and the Gaza Strip, often finds itself at the center of global attention. As we explore the significance of Rafah, we’ll uncover why all eyes are on Rafah and the complexities surrounding this pivotal region.
INTRODUCTION
What makes Rafah so significant that it captures global attention? The phrase ‘All eyes are on Rafah’ resonates not just with those in the region but with people worldwide who recognize its strategic, humanitarian, and political importance. In this guide, we will delve into the factors that make Rafah a focal point for international interest, examining its historical context, humanitarian challenges, and political dimensions.
Car Accident Injury Do I Have a Case....Knowyourright
Every year, thousands of Minnesotans are injured in car accidents. These injuries can be severe – even life-changing. Under Minnesota law, you can pursue compensation through a personal injury lawsuit.
How to Obtain Permanent Residency in the NetherlandsBridgeWest.eu
You can rely on our assistance if you are ready to apply for permanent residency. Find out more at: https://immigration-netherlands.com/obtain-a-permanent-residence-permit-in-the-netherlands/.
A "File Trademark" is a legal term referring to the registration of a unique symbol, logo, or name used to identify and distinguish products or services. This process provides legal protection, granting exclusive rights to the trademark owner, and helps prevent unauthorized use by competitors.
Visit Now: https://www.tumblr.com/trademark-quick/751620857551634432/ensure-legal-protection-file-your-trademark-with?source=share
In 2020, the Ministry of Home Affairs established a committee led by Prof. (Dr.) Ranbir Singh, former Vice Chancellor of National Law University (NLU), Delhi. This committee was tasked with reviewing the three codes of criminal law. The primary objective of the committee was to propose comprehensive reforms to the country’s criminal laws in a manner that is both principled and effective.
The committee’s focus was on ensuring the safety and security of individuals, communities, and the nation as a whole. Throughout its deliberations, the committee aimed to uphold constitutional values such as justice, dignity, and the intrinsic value of each individual. Their goal was to recommend amendments to the criminal laws that align with these values and priorities.
Subsequently, in February, the committee successfully submitted its recommendations regarding amendments to the criminal law. These recommendations are intended to serve as a foundation for enhancing the current legal framework, promoting safety and security, and upholding the constitutional principles of justice, dignity, and the inherent worth of every individual.
1. 1
The Polish Tax Code amendment process is
underway
In July, 2014 the minister of finance revealed the draft Tax Code bill.
It addresses many issues identified by the government as leading to (i) income leakages
from state budget (ii) ineffective tax collection.
The main modifications concern GAAR, tax rulings and penalty interest scheme.
Re-introduction of GAAR
GAAR was once present in the Polish tax law, but the Constitutional Tribunal repealed it
2004 (as GAAR wording was found unconstitutional).
It is claimed the new GAAR was prepared after the insightful analysis of the
Constitutional Tribunal ruling. The Minister of Finance says also, the proposed wording
of GAAR is similar to clauses present in other jurisdictions. The GAAR defines tax
avoidance as ‘a deliberate application of an artificial legal construct set up mainly to
achieve a tax benefit unintended by the tax regulations and contrary to these regulations’.
If an arrangement is classified as falling within GAAR’s scope, the tax office will be
entitled to assess the tax due as if the artificial arrangement was not in place. The
assessment will be made in reference to another arrangement that would typically be
used instead of the artificial one (provided the tax office will be able to show what typical
arrangement would be used).
The explanatory memorandum accompanying the draft bill gives a list of several
arrangements the minister of finance expects to be caught by the new GAAR. Hopefully,
the arrangements will be questioned only if they are found to be ‘artificial’. However, one
has to take into account any ‘untypical’ schemes, in particular these involving items listed
below will by default draw the tax office’s attention after the GAAR is introduced:
• hybrid financing arrangements,
• trusts,
• any entities domiciled in tax havens (in particular holding intangible assets such
as copyright, trademarks, image rights),
• artificial holding entities located in Cyprus, Slovakia, Luxembourg or similar
jurisdictions,
• Singaporean Qualifying Debt Securities (QDS) or similar securities.
The introduction of advanced opinions confirming non-applicability of GAAR to a given
arrangement is also considered. Unfortunately, the fees for issuing such opinions will be
significant.
Tax rulings
As these are inexpensive and offer good protection from any future tax assessments, there
are tens of thousands of individual rulings currently issued by the minister of finance.
2. 2
The tax rulings system is to be modified in the following ways:
• the rulings will not offer protection from any arrangements which may be subject
to GAAR,
• it will be possible to file for joint rulings (where several parties are engaged in one
transaction, one of them asks for a ruling which will apply to all the parties),
• general tax law interpretations are to be used on a wider basis – if any individual
tax law ruling is recognized by the Minister of Finance as covered by the general
tax law ruling – a note confirming the applicability of the general tax law ruling
will be issued.
Penalty interest
In short, steps undertaken with this respect focus on:
• 50% of penalty interest rate (currently the rate is at 10% p.a.) reduction for
taxpayers which self-correct their tax settlements within 6 months of filing the tax
returns,
• 200% of the standard penalty rate for tax fraudsters, who are defined as either
VAT or excise duty taxpayers who either do not file their tax settlements (do not
report turnover subject to these taxes) or declare tax amounts which are
significantly lower than what they should be (which means that there is a
difference of more than 25% between tax declared and tax that should have been
declared).
Initially it was planned the Tax Code modifications will enter into force on 1 July 2015.
Now the deadline is postponed until 1 January, 2016.
For any questions concerning the above contact our partners:
Maria Kukawska, partner Mariusz Machciński, partner
maria.kukawska@stonefeather.pl mariusz.machciński@stonefeather.pl