First published in Global Tax Weekly, 18 August 2016 The Belgian Parliament has enacted a series of new rules on transfer pricing (TP) documentation, which will have a substantial impact on the substance and format of TP documentation (Program Law of July 1, 2016, published in the Belgian
On 10 July 2015, the Dutch Supreme Court rendered an important verdict regarding the comparability of foreign investment companies with Dutch fiscal investment companies (“fiscale beleggingsinstellingen, or fbi’s”).
Taxand USA outlines the impact of the introduction of CbC into US regulations, and details essential steps that in-house tax teams should be taking now to prepare for the mandatory CbC filing requirements.
After months of discussions, the new General Anti-Avoidance Rule (hereinafter: “GAAR”) came into force on July 15, 2016. Taxand Poland provides an overview.
Taxand UK discuses the new guidance in the Country-by-Country reporting programme.
Taxand, the world's largest global organisation of tax advisors to multinational businesses, has been shortlisted for 11 International Tax Review (ITR) Americas Tax Awards for 2016, across 10 categories.
First published in BNA Bloomberg Tax Planning International, 30 July 2016. Under BEPS, the global tax landscape for multinational companies is subject to fundamental reform, the principles of which have been substantially agreed by over 60 OECD Member States.
Taxand South Africa explores the possibility of paying VAT on delivered goods. It is common practice for suppliers to deliver the goods that they supply at the premises of their customers on the customer’s request.
Taxand USA presents an update on the IRS proposed regulations under Section 385. On 25 July 2016, the IRS posted a revised version of a previously issued Chief Counsel Notice making it clear that any case in exam or litigation raising an issue under Internal Revenue Code Section 385 must
Taxand Greece highlights recent changes to Greek laws on: Investment incentives – A new law on investment incentives intended to promote regional economic growth and compatible with EU regulations Intra-group services – Amendments to the cost-plus regime applicable in respect of int
Taxand Argentina outlines treatment of recently issued US dollar denominated Argentine sovereign debt.
Taxand USA provides examples of how tax can integrate with other company business functions to drive value. Every organisational event has a tax impact, yet tax is rarely integrated with other business functions within a company.
The much-awaited Goods and Services Tax (GST) is closer to becoming a reality as the Constitution (122nd Amendment) Bill, 2014 (the Bill) has received its unanimous nod from the Upper House of the Parliament. Taxand India investigates further. The Bill paves the way for a uniform tax
Taxand Romania discusses amendments to Order no.
The draft law on the 2017 Luxemborg tax reform was presented to Parliament on 26 July 2016. Taxand Luxembourg outlines the main tax changes to both companies and individuals based on the draft law. While most of the tax measures to be introduced are in line with the announcements mad
In 2004, Congress enacted Section 409A of the Internal Revenue Code, which places strict requirements on nonqualified deferred compensation plans. Since then, the IRS has issued numerous pieces of guidance.
Taxand Luxembourg presents an overview of the Luxembourg tax reform. The law which introduced the first tax change announced by the Luxembourg Government back on 29 February and 21 April of this year was passed by the Parliament on 14 June and will apply as from 1 July 2016.
Taxand Argentina provides a summary of the Voluntary Disclosure Act. On 22 July 2016 the Voluntary Disclosure Act was published in the Official Gazette, which creates a voluntary and extraordinary disclosure regime and introduces significant changes to personal asset tax and income tax.
Taxand South Africa investigtes SARS' recent release of the following binding private rulings (BPR), binding class ruling (BCR) and binding general ruling (BGR): BPR 230: Disposal of an asset in terms of an asset-for-share transaction within 18 months of its acquisition in terms of an
On 23 June 2016, the UK voted to leave the European Union. The immediate reaction across the UK and Europe, and indeed globally, has been one of shock as few predicted such a result.
On April 4, 2016, the IRS and Treasury released two sets of proposed and temporary regulations that caused various taxpayers, investment bankers and large sectors of the investment community, particularly in the pharmaceutical and biomed sectors, to sound alarm bells.
The referendum in the UK on whether to leave the European Union has produced a clear if close result in favor of leaving. Taxand UK considers the immediate impact of the result, the potential impact on the tax system in the UK and internationally, and the likely response from busines
Taxand South Africa provides the latest tax updates. ANGOLA: Securities Code Regulations enacted CAMEROON: Tax amnesty on property tax announced GABON: Finance Law 2016 – direct taxes KENYA: Budget and Finance Bill 2016 LESOTHO: new tax treaty with South Africa enters into force NIG
Taxand Romania discusses amendments to Order no. 3841/2015 regarding the approval of the model and content of form (088). Order of the president of National Agency for Fiscal Administration no. 2048/2016 published in the Official Gazette no.
On 14 July 2016, the US Treasury Department held its much anticipated hearing on the controversial proposed earnings stripping regulations under Section 385 of the Internal Revenue Code. Taxand USA attended the hearing on behalf of their clients and readers.
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