Search results for

Amazon has triumphed over the US tax authority after the US Tax Court ruled in favour of the online retailer in a tax dispute involving Amazon’s use of a Luxembourg subsidiary for its European operations and transfer pricing arrangements.

Anne Bennett On February 22, the South African Minister of Finance delivered the 2017 budget, which proposed raising an additional ZAR 28 billion ($2.2 billion) primarily by collecting ZAR 16.5 billion more in personal taxes and ZAR 6.8 billion through an immediate increase in the dividend withholding tax rate from 15% to 20%. Apart from any treaty relief, profits extracted from South African companies will now suffer an effective rate of 42.4% (up from 38.8%) once 28% corporate tax and 20% dividends tax is accounted for.

Maria Sarantopoulou Zoe Kokoni Cyprus adopted the "start-up visa" plan (start-up permit scheme) on February 15 2017 for third country nationals interested in residing and investing in innovative businesses in Cyprus.

Taxpayers must comply with the rules to qualify for the credit.

Gonzalo Gallardo At the end of 2016, a provision appeared in Royal Decree-law 3/2016 of December 3, introducing important changes to the Corporate Income Tax Law. Prior to that, Royal Decree-law 2/2016 of September 30 2016, had amended the prepayment system relating to this tax, establishing a minimum advance payment based on the income per books rather than the tax base. Both of those provisions are aimed at reducing the public deficit by immediately increasing the amount collected for corporate income tax, and mainly affect companies with high revenues and multinationals operating in Spain (large enterprises). In this commentary, we will highlight the three most relevant changes brought in by the new provision.

Jacques Kistler Rene Zulauf After the rejection of Corporate Tax Reform III (CTR III) by the Swiss electorate on February 12 2017, the Swiss Federal Council now plans to introduce revised legislation of the tax reform quickly and has instructed the finance ministry accordingly.

Barbara Scampuddu Gian Luca Nieddu Starting from 2017, non-resident individuals who transfer their place of residence to Italy may opt for a preferential tax regime with regard to foreign source income.

Because tax doesn’t have to be taxing. A less-than-serious look back at some of the quirkier tax stories from the past month.

Janina Fornalik The amendments to the Polish VAT Act, binding since January 1 2017, introduced new regulations regarding the reverse charge mechanism applicable to domestic supplies between two VAT payers consisting of construction works. However, additional specific conditions should be met, which in practice create a number of interpretation problems.

Jim Fuller David Forst A fundamental principle of US transfer pricing rules is that transactions structured between related parties are to be respected unless the transactions lack economic substance (see Treasury Regulations §§ 1.482-1(d)(3)(ii)(B) and (iii)(B)). This is an important rule that respects a central pillar of the US tax system – separate entities should be treated separately. The rule also contributes to predictability and stability in worldwide tax administration.