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Date Title
26 December 2013
Client/Legal Alert
For some time now there have been rumours on this subject. Pierre Moscovici (Minister of Economy and Finance) and Bernard Cazeneuve (deputy Budget Minister) have officially announced to the Rapporteurs and the Presidents of the Finance Commission (Commission to the National Assembly and to the Senate) that, “taking into account progress realized and answers actually addressed to the French queries in 2013, we wanted to inform you that as from now we will propose to have Jersey and Bermuda removed from the list of Non Cooperative States and Territories upon the update of the list in 2014” (free translation). The announcement is reassuring: in practice, French assets held by structures located in Jersey and Bermuda will not suffer the punitive measures of French taxation targeting Non Cooperative States and Territories.
24 December 2013
Client/Legal Alert
France is at the forefront of the implementation of a series of "anti-BEPS" measures, in relation to procedural aspects of tax examinations, general anti-abuse, transfer pricing, and the like. Below is a brief summary of the most salient measures recently adopted in relation to international tax and transfer pricing, up to date as of 20 December 2013.
December 2013
Client/Legal Alert
A new PRC Circular 642 will require PRC residents to report their foreign financial assets and liabilities as well as cross border transactions. The Circular was issued on 9 November 2013, and takes effect on 1 January 2014.
December 2013
Newsletter
This is the December 2013 issue of the European Tax Newsletter.
November 2013
Newsletter
This is the November 2013 edition of China Tax Monthly.
December 2013
Client/Legal Alert
The Tax Reform approved by the Mexican Congress presents several changes to the taxpayers, including the manufacturing sector, since it brings up a new Income Tax Law (ISR). The following concepts are amended, which we consider of great impact and relevance to the Maquiladora industry, considering that today they have not issued regulations or decrees that might reduce or mitigate the impact of the reform.
December 2013
Client/Legal Alert
The State Finance Department submitted a Revenue Bill to the Chihuahua State Legislature for the 2014 fiscal year. Among other things, the bill provides for a 1% increase to the payroll tax. The current payroll tax rate under the Chihuahua State Tax Code is 2 percent, while the executive bill proposes a hike to 3 percent, meaning that, if enacted, taxpayers would see a 50 percent increase in their payroll tax burden.
December 2013
Client/Legal Alert
On 1 January 2014, significant changes related to corporate property tax will come into force. According to Law 307-FZ, the tax base of certain types of real property shall be calculated based on their cadastral value. Currently the tax base is calculated based on the annual average net book value of real estate.
December 2013
Client/Legal Alert
At a time when transfer pricing is at the forefront of the international tax debate, the Dutch Ministry of Finance published a new transfer pricing decree on 26 November 2013 (no. IFZ2013/184M) (the "Decree").
December 2013
Client/Legal Alert
With the Law of 30 July 2013, the Belgian government has introduced a new reporting obligation for individual resident founders and beneficiaries of legal arrangements. The concept of “legal arrangement” covers (i) trusts, foundations and similar structures; and (ii) certain tax haven companies mentioned on a black list (to be determined by Royal Decree). Please see our previous tax alert in this respect. In the meantime, a draft Royal Decree with the black list of tax haven companies has been prepared by within the government.
November-December 2013
Article
Those of us of a certain vintage may recall the old Art Linklater radio/television program, “House Party,” which had a recurring, humorous feature known as Kids Say the Darndest Things in which Art posed various questions to young children. (The series, which ran from 1945 to 1969, was also resurrected and reprised by Bill Cosby in the late 1990s.) The answers were hilarious as the kids often didn’t understand the question asked, misinterpreted the question or just flat out engaged their wonderful imaginations. The incongruity between the questions and answers gave rise to many smiles and chuckles. The authors recently were reminded of this show while reading the comments made by Bill Morgan, the Senior Economic Adviser to the APMA Program, at a Bloomberg BNA function in July 2013.1 In particular, we read with interest Morgan’s lament over the Tax Court’s opinion in VERITAS Software Corp. v. Commissioner.
December 2013
Client/Legal Alert
Today, 26 December, 2013, the Ministry of Finance and Public Credit issued a Decree granting Tax Incentives to companies of the Manufacturing and Export Maquiladora Industry (Decree). This publication is consistent with the statement released previously by the National Council Maquiladora and Export Manufacturing Industry as one of the important achievements after the legislative process of the recent Tax Reform that will enter in full force on 1 January, 2014. In summary, the Decree includes the following benefits for Maquiladora companies to mitigate some of the effects of the Tax Reform that would have reduced the international competitiveness of the industry.
December 2013
Newsletter
This edition of the Private Banking Newsletter contains wealth management-related updates and legal developments from countries across five continents.
December 2013
Client/Legal Alert
The Tax Administration Service (SAT) recently published regulatory criterion 00/20413/ISR. Acts or transactions prohibited by the Federal Law for the Prevention and Identification of Transactions with Funds from Illegal Sources. Participating in such acts or transactions entails the impossibility to deduct expenses related to them, which establishes that those actions conducted by taxpayers in contravention of the provisions of article 32 of the Federal Law for the Prevention and Identification of Transactions with Funds from Illegal Sources (the Law) will not be deductible for Income Tax purposes.
December 2013
Client/Legal Alert
Today, 6 December 2013, the National Council of the Manufacturing and Export Maquiladora Industry (INDEX) summarized important achievements during the legislative process of the recent Tax Reform, that will enter into force and effect on 1 January 2014. INDEX also announced that the Ministry of Finance and Public Credit will publish within the following days a Decree granting, among others, the following benefits to mitigate some of the effects of the Tax Reform that reduce the international competitiveness of the maquiladora industry.
 
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