Search results for

On February 18 2010, in the case "The Director, Mauritius Revenue Authority v Mega Design Limited", the Supreme Court of Mauritius reaffirmed that where supply of services are made to a person outside Mauritius according to paragraph 6 of the fifth schedule of the Value Added Tax Act (VAT Act), these services would be treated as zero-rated.

Eric Roose Takeo Mizutani Foreign investors purchasing real estate in Japan directly through a Japanese company can expect to pay an effective tax rate of as much as 54% on repatriated earnings and gains. To reduce these very high rates of taxation, foreign investors in Japan generally invest through one of two structures, the Tokutei Mokuteki Kaisha (TMK) structure or the Tokumei Kumiai (TK) structure.

Elena Kostovska The last months of 2009 brought in changes to the FYR Macedonian law on VAT. Both VAT registered and non-registered companies will find that the law may affect them, either by the introduction of different registration deadlines, VAT submission statements, and changes to the transfers of assets VAT treatment or VAT reductions in certain real estate sales.

Sabrina Wong Josh Jones The fifth protocol to the Canada-US income tax convention (the treaty) introduced a rule in article IV(6), generally effective for years beginning after 2008, relating to fiscally transparent entities, most notably US limited liability corporations (LLCs). Interpreting this rule has caused considerable confusion.

Rajendra Nayak Ganesh Pai The Authority for Advance Rulings (AAR) in India, in the case of Amiantit International Holding Limited [2010-TIOL-07-ARA-IT] recently ruled on the issue of whether the transfer of shares in an Indian company for no consideration is taxable under the Income-tax Act, 1961 and whether transfer pricing provisions apply to such transfers.

Simeon Grigorov Phani Tillirou At the end of last year Bulgaria adopted a new inclusive box of amendments to the corporate income tax act (CITA) bringing about significant changes, the vast majority of which came into force on January 1 2010. The tax box contains numerous changes on the wide range of sections covered by the CITA.

Nélio Weiss Philippe Jeffrey With the enactment of new thin capitalisation rules at the end of December 2009, many Brazilian entities will be forced to review their financing structure and find alternatives to counteract the potential loss of a portion of their current interest tax deduction. Under the new rules, the amount of debt granted by related parties cannot exceed twice the amount of the participation in the net equity of the Brazilian entity (2:1 ratio). For debts with entities located in a tax haven or favourable tax regime jurisdiction, the amount of debt cannot exceed 30% of the Brazilian entity's net equity.

If enacted, amendments to Spanish law will increase the penalties for tax fraud, such as a longer prison term and direct liability for companies, and give the tax authorities more time to investigate cases. However, the changes will also add uncertainty for taxpayers, explain Oscar Morales and Manuel Álvarez of Uría Menéndez

It is not known if the Swiss bank will deliver on the demands UBS, the international bank, has told shareholders it has received requests for customers' tax information from a number of countries, including the UK, Canada and Australia.

Jack Grocott