International Tax News Blog

Archives: 2014

Subscribe
  • French Budget Revision Modifies Rules On Tax Consolidations to Comply With EU Ruling

    by Rick Mitchell

    France has published a 2014 budget revision law that allows related French companies to opt for tax consolidation with one another, even when their parent company is located in another European Union state.
    Companies affected by the change in the country's “fiscal unity” regime may be eligible for reimbursement of French corporate taxes paid in fiscal years 2011-13, practitioners said.

    For the story, go here. (subscription required)

    By Mitchell, Rick, posted on Monday January 5, 2015
  • Disruptive Supply Chain Trends in the Evolving Tax Environment

    by Peter Anderson, Wes Cornwell, Yvonne Metcalfe, and Alex Ward

    Peter Anderson, Wes Cornwell, Yvonne Metcalfe and Alex Ward of EY write that global supply chains are changing rapidly—and a range of emerging trends will have significant impacts on both the physical supply chain and the broader business and tax operating model. The authors look at considerations arising with 3-D printing and other manufacturing developments, big data, supplier and customer collaboration, enhanced procurement, end-to-end cost optimization and supply chain segmentation.

    For the article, go here. (subscription required)

    By Anderson, Peter and Wes Cornwell, Yvonne Metcalfe, and Alex Ward, posted on Monday January 5, 2015
  • Colombian government passes major tax reform, including rate increases and new taxes

    by PwC

    The Colombian government has passed a major tax reform package that introduces a temporary net wealth tax assessed on net equity on domestic and foreign legal entities, repeals the previously scheduled rate decrease for the income tax on equality (CREE for its Spanish acronym), introduces a CREE surcharge until 2018, and increases domestic law income tax withholding rates on cross-border payments, among other significant changes.

    For the PwC Insight, go here.

    By PwC, posted on Monday January 5, 2015
  • Will Foreign Tax Credits Be ‘LOST’ at Sea?

    by Alan S. Lederman

    The International Seabed Authority is in the process of preparing regulations specifying the payments to be required from foreign companies for deep-sea mining concessions. Some experts estimate that in the long term, mining concessions granted by the authority may produce trillions of dollars of minerals, so these regulations can eventually have a very large economic impact. For U.S. parent companies of foreign mining subsidiaries that engage in authority-licensed deep-sea mining, a crucial question is whether the IRS will allow them to claim an income tax credit for the amounts charged by the authority to those foreign subsidiaries. Alan S. Lederman of Gunster, Yoakley & Stewart writes that under existing U.S. tax law the IRS is unlikely to concede an income tax credit for the payments required by the authority.

    For the Insight, go here. (subscription required)

    By Lederman, Alan S., posted on Monday January 5, 2015
  • Spain approves major tax reform

    by PwC

    The Spanish government, on November 27, 2014, passed Laws Nos. 26 and 27 amending the Personal Income Tax Law, the Nonresident Income Tax Law, and the Corporate Income Tax Law. The new provisions will generally come into force for tax years beginning on or after January 1, 2015.
     
    While the amendments to the corporate income tax regime reduce the tax rate, they also introduce measures to limit the deductibility of certain costs and the use of net operating losses. The amendments also introduce some measures in line with the OECD's base erosion and profit shifting (BEPS) project.

    For the PwC Insight, go here.

    By PwC, posted on Tuesday December 23, 2014
  • 4 More Reasons to Question U.S. Territorial Tax Adoption

    by Patrick Driessen

    Patrick Driessen provides four reasons to be cautious about the adoption of a territorial tax system by the United States.

    For the viewpoint, go here.

    By Driessen, Patrick, posted on Monday January 5, 2015
  • Stock Lending Notices, Unwritten Intent, and Economic Substance

    by Mike Gaffney

    Mike Gaffney calls for the withdrawal of a 2012 generic legal advice memorandum that he believes inappropriately applies the economic substance doctrine in the tax ownership area of fungible securities.

    For the report, go here. (subscription required)

    By Gaffney, Mike, posted on Monday January 5, 2015
  • News Analysis: International Audit Trends

    by Lee A. Sheppard

    In news analysis, Lee A. Sheppard reports on recent IRS Large Business and International Division audit practices and other guidance discussed at the International Fiscal Association USA New York branch seminar on December 18.

    For the story, go here. (Subscription required)

    By Sheppard, Lee A., posted on Monday January 5, 2015
  • Spain approves major tax reform

    by PwC

    The Spanish government, on November 27, 2014, passed Laws Nos. 26 and 27 amending the Personal Income Tax Law, the Nonresident Income Tax Law, and the Corporate Income Tax Law. The new provisions will generally come into force for tax years beginning on or after January 1, 2015.

    While the amendments to the corporate income tax regime reduce the tax rate, they also introduce measures to limit the deductibility of certain costs and the use of net operating losses. The amendments also introduce some measures in line with the OECD's base erosion and profit shifting (BEPS) project.

    For the PwC Insight, go here.

    By PwC, posted on Monday January 5, 2015
  • Discussion drafts released in six BEPS - related area raise more concerns for MNEs

    By PwC

    Multinational enterprises (MNEs) may be concerned about various aspects of the six Discussion Drafts released last week as part of the Base Erosion and Profit Shifting (BEPS) Action Plan.

    Three of the papers are within Action items 8 to 10 of the BEPS Action Plan dealing with assuring that transfer pricing outcomes are in line with value creation. One of the other papers is the first step towards producing best practice rules to address base erosion and profit shifting through the use of interest expense within Action item 4 of the Plan. The latest proposed additions to the draft International VAT/GST Guidelines relate to supplies of services and intangibles to consumers, raised in the initial report on the digital economy within Action 1. The final paper is an overarching look at the resolution process involving cross-border tax disputes.

    For the PwC Bulletin, go here.

    By PwC, posted on Monday January 26, 2015


Read More International Tax News