December 2017 Issue
Ever changing and increasingly complex, global tax systems are subject to constant volatility and fluctuation, with a number of legislative reforms having a significant impact in recent times. Indeed, on the heels of new and updated legislation, tax authorities around the world are becoming more sophisticated, enhancing their audit activity and are making greater use of tax information exchange agreements to avoid damaging tax practices, as well as helping to promote global cooperation in tax matters. Going forward, the convergence of global tax practices will continue its goal of incorporating best practice into tax regimes worldwide. Companies need to respond accordingly, with sound tax plans and practices that maintain compliance.
FORUM: Managing tax disputes in the Asia-Pacific region
FW moderates a discussion on managing tax disputes in the Asia-Pacific region between Rachanee Prasongprasit at LawAlliance Limited, Liesl Fichardt at Quinn Emanuel Urquhart & Sullivan, LLP, and Vijey M. Krishnan at Raja, Darryl & Loh.
A new era of international tax disputes and arbitration?
Quinn Emanuel Urquhart & Sullivan The growing focus on multinationals and their tax affairs by governments across the world is likely to result in increased tax disputes at a domestic level and, in many cases, arbitration at an international level. This introduces a new era in which we are likely...
McDermott Will & Emery LLP One significant consequence of the financial crisis was greater scrutiny of the techniques and cross-border structures used by major multinational groups to reduce their effective tax rates. Increasingly, cash-strapped governments have seen an...
The rise of general anti-avoidance rules in taxation
Bär & Karrer Fighting tax avoidance and the closing of tax loopholes are high on the agenda of many countries, as well as multilateral organisations such as the European Union or the Organisation for Economic Co-operation and Development (OECD). While tax...
Policing the evaders and facilitators: new corporate offences relating to tax evasion
CMS On 30 September 2017, the new corporate criminal offences of failure to prevent the facilitation of both UK and foreign tax evasion under Part 3 of the Criminal Finances Act 2017 came into force. The Act establishes two new offences, dealing respectively...
Tax rulings and state aid: where are we now?
Slaughter and May Following a period of relative quiet, the European Commission’s output from its state aid investigations into tax rulings and special tax regimes seems to be ramping up again, with Luxembourg in particular under fresh scrutiny...
Responding to government tax audit, inquiry and investigation: a French perspective
Cabinet Derouin In recent years, the French tax authorities have been increasingly inquisitive with international businesses and investors doing business or providing goods and services in France or to be used in France. Hundreds of inquiries have been initiated...
Further modernisation of tax procedures in Cyprus
Elias Neocleous & Co LLC Prior to 2014, direct taxes such as income tax and capital gains tax in Cyprus were administered by the Inland Revenue department and VAT was administered by the VAT department. In 2014, the two departments were merged to create a single...
Poland to amend both income tax laws to modify CFC Rules in 2018
GESSEL The Controlled Foreign Corporation (CFC) regulations have been introduced in Poland for the first time and are based upon the law dated 26 June 2014, which amended the 1992 Corporate Income Tax Law and the 1991 Personal Income Tax Law...
PJS Law Six ASEAN member countries are already members of the Organisation for Economic Co-operation and Development’s (OECD) Base Erosion and Profit Shifting (BEPS) Inclusive Framework (BEPS Associates) as of October 2017. Brunei Darussalam...
Corporate tax developments in Indonesia
ABNR This article provides an update on corporate tax developments in Indonesia, covering automatic exchange of information, anti-tax treaty abuse, controlled foreign company and the Indonesia-Netherlands double taxation avoidance (DTA) agreement...
Q&A: Transfer pricing – meeting the demand for transparency
FW moderates a discussion on meeting the demand for transparency in transfer pricing between Luis Abrantes at Carlsberg, Joanna Gniadecka at Liberty Global B.V., David Sayers at Mazars LLP, and Nathaniel Carden at Skadden, Arps, Slate, Meagher & Flom LLP.
CONTRIBUTORS
ABNR
Bär & Karrer
Cabinet Derouin
Carlsberg
CMS
Elias Neocleous & Co LLC
GESSEL
LawAlliance Limited
Liberty Global B.V.
Mazars LLP
McDermott Will & Emery LLP
PJS Law
Quinn Emanuel Urquhart & Sullivan, LLP
Raja, Darryl & Loh
Skadden, Arps, Slate, Meagher & Flom LLP
Slaughter and May