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WEB2 days ago · ITR World Tax rankings released: big EMEA performance for ‘big four’. Tom Baker, September 10, 2024. This week in tax: Ireland progresses with new participation exemption. Ralph Cunningham, August 30, 2024. This month in indirect tax: UK parties say no to higher VAT. Ralph Cunningham, June 05, 2024.
US tax treaty shopping rules: Traps for the unwary
WEBMay 31, 2012 · The ownership/base erosion test invariably includes two elements. First, at least 50% of the aggregate voting power and value of a company's stock must be owned, directly or indirectly, by persons who share the company's country of residence and who are otherwise entitled to treaty benefits under the LOB article (provided that any such company must meet the publicly traded company test).
The implications of the credit crunch for intercompany loans
WEBFeb 24, 2009 · The rise in interest rates on corporate debt is reflected in Bernanke’s observation that credit spreads have risen to “ unprecedented levels ”. While many multinational corporations with inbound intercompany loans may have relied on the applicable federal rate (AFR) safe haven of section 1 …
Beyond M&A: The evolution of tax liability insurance
WEBSep 22, 2020 · The number of W&I policies written by the global mergers and acquisitions (M&A) insurance market has increased approximately 20% year on year for the last decade. Based on information from insurers, there were over 6000 policies placed in 2019 globally. There were more than 500 tax enquiries sent to the …
Targeting indirect share transfers by foreign investors
WEBAug 31, 2010 · Article 5 of circular 698 requires a foreign investor to report the indirect transfer of a resident enterprise to the tax authorities in China within 30 days after signing the share sale agreement if the actual tax burden in the intermediate holding company's jurisdiction is less than 12.5%, or if that jurisdiction exempts foreign-sourced income from tax.
How Indian indirect tax laws align with OECD guidelines
WEBJul 8, 2014 · Tel: +91 124 6711022. Fax: +91 124 4644050. Email: [email protected]. Website: www.in.ey.com. Saurabh is a senior tax professional in the indirect tax practice of EY. He has about six years of experience in advising his clients in various indirect tax laws.
Case study: Determining the benefits of profit splits
WEBOct 24, 2019 · Determining the benefits of profit splits. The European consumer goods company decided to use the profit split method after carefully weighing up the pros and cons of each TP method. The profit split method had to meet a series of standards to become the main method for certain transactions. …
A brave new world in tax transparency: CRS in China, Hong Kong …
WEBNov 28, 2017 · Increasing cross-border business and investment has made the holding of assets overseas through offshore accounts increasingly common. This has become a new tax battleground for businesses and governments. Charles Kinsley, Henry Wong, and Eva Chow look at the latest developments regarding these efforts in …
Understanding the beneficial ownership v. beneficial holding …
WEBSep 14, 2021 · The concept of ‘beneficial ownership’ is found under the international tax treaties. The tax treaties are negotiated based on the model tax conventions and these conventions inter alia provide explanations as to the intent and purpose behind terms appearing therein. The phrase ‘beneficial owner’ appears in both the OECD Model Tax Convention and the UN Model Tax Convention in the ...
Insights for tax leaders: KPMG CEO Outlook Pulse Survey
WEBJul 16, 2021 · From January 29 to March 4 2021, 500 CEOs in 11 key markets (Australia, Canada, China, France, Germany, India, Italy, Japan, Spain, UK and US) were asked to provide their three-year outlook on the economic and business landscape, as well as the ongoing COVID-19 pandemic, as captured in the …
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