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Date Title
February 2015
Article
As of 2015, the place of supply of electronic and telecommunication services provided to non-taxable persons will be the place of establishment of the purchaser of the service. This will cause difficulties for companies providing such services; the legislator tries to limit the difficulties by implementing various simplification measures, such as the mini one stop shop.
February 2015
Client/Legal Alert
In late 2009, the PRC tax authorities issued their most influential and also most controversial anti-avoidance tool, Notice 698, to combat indirect transfers designed by offshore investors to avoid paying the 10 percent capital gains tax on the direct transfer of equity interests in Chinese resident enterprises. On 6 February 2015, the State Administration of Taxation finally released the long-awaited replacement rules for Notice 698 (Indirect Transfer Regulation). While, as expected, the Indirect Transfer Regulation provides a safe harbor for intragroup reorganizations, the Indirect Transfer Regulation introduces many other significant and controversial measures, such as imposing a withholding obligation on offshore buyers potentially before the tax authorities have even determined taxability, expanding the scope to tax indirect transfers of real properties and properties owned by an "establishment or place", deeming certain indirect transfers as lacking reasonable commercial purpose without going through a more full analysis and requiring sellers to pay tax while imposing penalties even before the tax authorities have determined whether the underlying transaction is taxable.
16 January 2015
Client/Legal Alert
The Australian Government has recently released exposure draft legislation impacting the taxation of employee share schemes (ESS). Interested parties are invited to submit their comments on the draft legislation by 6 February 2015.
9 January 2015
Newsletter
This is the January 2015 edition of the Paris Tax Newsletter.
January 2015
This is the January 2015 edition of the Paris Tax Newsletter.
January 2015
Newsletter
This is the January 2015 issue of the European Tax Newsletter.
2015
Book
Baker & McKenzie Handling Tax Disputes in Europe 2015 handbook addresses a number of major issues for 17 of the European countries on what to do when anticipating, preparing for, and managing tax disputes in Europe. It also provides detailed information about litigation before the European Court of Justice, the competent authority process, and the use of the European Arbitration Convention.
23 December 2014
Client/Legal Alert
A recent decision of the High Court allows the State Revenue to levy duty on payments made to a vendor of land for building services supplied after completion of the land sale contract (Commissioner of State Revenue (Vic) v Lend Lease Development Pty Ltd [2014] HCA 51). The duty base therefore included both the purchase price for the land and the additional payments for services.
December 2014
Newsletter

In this Issue:

  • Final GRA Regulations: A Mixed Bag
  • Old But Not Forgotten: Adjustments to Annual Layers of Pre-1987 Foreign Income Taxes
  • ECD Delivers Two New Discussion Drafts as Part of Its Action Plan on Base Erosion and Profit Sharing
  • Notice 2014-58: Economic Substance Guidance Lacks Substance
  • Canadian Tax Update
  • Ready for Another Round? Michigan's Second Retroactive Repeal of the Multistate Tax Compact Election
  • A Real Game Changer?: Temple Inland v. Cook and the Future of Unclaimed Property in Delaware
  • Baker & McKenzie Announces Three Important Seminar Opportunities in the Coming Months
December 2014
Client/Legal Alert
On 28 November 2014, Kazakhstan adopted certain amendments to its tax legislation. Most of the Tax Amendments take effect on 1 January 2015. 
28 November 2014
Client/Legal Alert
A new bill introduced into the Parliament of Queensland creates a new concession for farm-in agreements. The new concession is intended to remove from the duty base the amount paid for exploration by the acquirer of an interest in an exploration right under a farm-in agreement. In the absence of such a concession, duty would be payable on a farm-in agreement on the amounts spent on exploration.
24 November 2014
Article
This article is authored by Arseny Seidov and is reprinted from Tax Notes Int’l.
November 2014
Client/Legal Alert
The deoffshoring law was adopted in the second and third readings by the State Duma on 18 November 2014, and approved by the Federation Council on 19 November 2014.
November 2014
Client/Legal Alert
Investigators have been given back the power to initiate criminal cases for tax offences. This opens the door to investigation of tax violations for the previous 10-year period and creates a higher risk of arbitrary initiation of criminal cases and raids for alleged tax offences regardless of whether any tax underpayment has been assessed by the tax inspectorate.
November-December 2014
Newsletter
This is the November and December 2014 edition of the Paris Tax Newsletter.
 
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