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Date Title
February 2014
Client/Legal Alert
On 11 February 2014, the Canadian Federal Minister of Finance (Minister) released his 2014 Budget and among the proposals was an announcement to end the so-called “immigration trust” – in some circumstances, immediately.
February 2014
Client/Legal Alert
Business Competition Supervisory Commission (KPPU) has been considering amending the Anti-Monopoly Law for years. In January 2014, an agenda item to amend the Anti-Monopoly Law was added to the National Legislation Program of the House of Representatives for discussion in 2014 along with 65 other draft laws. There is no assurance that the House of Representatives will pass the amendment in 2014 and issues may be added on or dropped during the House of Representatives' deliberation.
January 2014
Featured Content
TaxShare: Tax Dispute Resolution Resource is an online tool to assist our clients and friends in successfully managing, settling and if necessary, litigating tax disputes to a successful conclusion.
30 January 2014
Client/Legal Alert
A recent decision of the Constitutional Court declares parts of the Belgian lump-sum foreign tax credit regime unconstitutional.
December 2013
Client/Legal Alert
This is the December 2013 edition of China Tax Monthly.
January 2014
Client/Legal Alert
On 25 December 2013, the General Administration of Customs of the People’s Republic of China (GAC) issued two new regulations on customs valuation, both effective from 1 February 2014. GAC Order No. 213 (Order 213), entitled Measures of Customs of the People’s Republic of China for the Determination of Dutiable Value of Imports and Exports, will replace the existing regulation with the same title issued under GAC Order No. 148 on 28 March 2006 (Order 148). In addition, GAC Order No. 211 (Order 211), entitled Measures of Customs of the People’s Republic of China for the Determination of Dutiable Value of Domestic Sales of Bonded Goods, is an entirely new regulation specifically providing for the valuation of bonded goods sold within the territory of China.
8 January 2014
Client/Legal Alert
About 300 Belgian companies and branches are expected to receive a standard transfer pricing questionnaire in the coming weeks and be subject to an in-depth transfer pricing audit in 2014.
January 2014
Client/Legal Alert
On 31 December 2013, the State Encryption Management Bureau (SEMB) issued Announcement No. 27 and adjusted the Catalogue for the Administration of Import of Encryption Products and Equipment Containing Encryption Technology (the “Adjusted Catalogue”), replacing the Catalogue for the Administration of Import of Encryption Products and Equipment Containing Encryption Technology (First Batch) annexed to SEMB Notice No. 18 and effective on 1 January 2010 (the “Original Catalogue”). The new Catalogue is effective from 1 January 2014.
January 2014
Newsletter
This information bulletin is published by the Baker & McKenzie Tax Group.
January 2014
Client/Legal Alert
In 2010 Congress enacted section 1298(f) with the seemingly simple requirement that each US person who is a shareholder of a passive foreign investment company (PFIC) file an annual report. This filing requirement was effective as of 18 March 2010.
January 2014
Article
Globalization and the current economic climate have forced states to work toward improving access to foreign and domestic tax information with a view to better protecting their own tax bases. At the forefront of these efforts are the exchange-of-information provisions found in virtually all bilateral tax treaties, many of which are based on the OECD's model double taxation convention. Curiously, existing departures from the OECD model suggest that certain states may have the obligation to assist one treaty partner by requesting and providing tax-related information from another treaty partner. This article analyses the viability of this “treaty network theory” in the context of the OECD model and Canada’s existing tax treaties. The author concludes that the text of many of Canada’s treaties appears to allow for such a result, suggesting that tax authorities and treaty negotiators should carefully consider whether this was intended, or whether they should protect against this possibility in their future work.
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.
 
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