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Date Title
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
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
Newsletter
This information bulletin is published by the Baker & McKenzie Tax Group.
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.
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.
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.
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.
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
Newsletter
This is the December 2013 issue of the European Tax Newsletter.
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
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.
November 2013
Newsletter
This is the November 2013 edition of China Tax Monthly.
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
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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