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      Tuesday 24 September 2019
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      Articles

      Article September 2019

      Swiss Patent Box

       

      Due to The Federal Act on Tax Reform (TRAF), Swiss special income tax regimes considered harmful (in particular holding companies, mixed companies and domiciliary companies) will be abolished by 1 January 2020 and replaced by internationally accepted measures. 

      Article September 2019

      Brazilian companies seeking alternative approaches to restructuring in tough economic conditions

       

      Many Brazilian companies, particularly in sectors such as construction, infrastructure and retail, which depend to a large extent on the internal Brazilian market, are still suffering from the impact of the 2015/16 recession.

      Article August 2019

      When does an Australian tax resident (non-U.S. tax resident) need to lodge a U.S. tax return?

       

      A Non-Resident Alien (NRA) of the United States generally needs to file a U.S. tax return under one of four scenarios.

      Article August 2019

      The Malta Ukraine double taxation agreement

       

      Malta is one of the countries having a favourable double taxation agreement with Ukraine which was ratified by the Government of Malta in December 2017. The treaty became effective on the 28 August 2017, and provides for the following reduced rates of withholding taxes for dividends, interest and royalties paid by a Ukrainian company to a Malta company.

      Article August 2019

      Malta introduces group tax consolidation rules

       

      On 31 May 2019, by means of legal notice 110 of 2019, the Consolidated Group (Income Tax) Rules, 2019 (hereinafter “the Rules”) have been enacted which provide for an optional tax consolidation of companies forming part of a group, as defined in the rules. 

      Article August 2019

      Intercompany services – rendered or not rendered?

       

      Non-French tax residents whose sole French income is furnished rental income exceeding EUR23,000 should be subject to professional furnished rental tax scheme leading to specific French tax and social impacts.

      Article August 2019

      International Tax Handbook Update – Finance Act, 2019

       

      Finance Act, 2019, the memorandum containing amendments made in taxation by the Parliament of Pakistan. Please click here to view the tax chapter.

      Article August 2019

      Australia’s Penal Taxation of Foreign Trusts

       

      Under Australian tax law, if a foreign trust accumulates foreign income and capital gains; and later distributes that income to an Australian tax resident beneficiary, in most cases, the beneficiary is taxed the distribution. The taxable amount is reduced by the original settlement into the trust and other exceptions exist.

      Article August 2019

      Portugal - Update of the transfer pricing regime

       

      After almost 20 years since the enactment of the Portuguese transfer pricing regime, an update for this regime was recently approved by the Portuguese parliament (included in the Corporate Income Tax (CIT) Code), but also of the General Taxation Infringement Regime (associated with the penalties for non-compliance).

      Article August 2019

      Key challenges faced by taxpayers on preparation of transfer pricing documentation

       

      Despite issuing regulations on how the transfer pricing (TP) rules should be applied, many taxpayers are still not familiar with the transfer pricing regulations enacted in 2014 and revised in 2018.

      Article August 2019

      News on the French furnished rental tax scheme

       

      Non-French tax residents whose sole French income is furnished rental income exceeding EUR23,000 should be subject to professional furnished rental tax scheme leading to specific French tax and social impacts.

      Article July 2019

      Pacte Bill 2019

       

      Pacte Bill 2019 - New rules governing the exemption from statutory pension contributions for employees assigned in France since July 2018.

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