Ilyashev & Partners has been successful in numerous litigations with the tax authorities and the Main Control and Revision Office of Ukraine.
Schoenherr’s tax practice group advises domestic and international clients on their most sophisticated and challenging tax matters.
Tax Newsletter — Serbia: rulebooks on tax balance and tax returns for corporate taxpayers and entrepreneurs download
Karanovic & Nikolic has published the March 2014 edition of its Tax Newsletter.
From 6 April 2014, LLP members will be taxed as employed if less than 20 per cent of their remuneration is linked to the overall profitability of the LLP.
Riaz Karamali, a partner in Pillsbury’s Silicon Valley and San Francisco offices who represents emerging growth companies, answers some common questions innovators face.
HMRC has published updated guidance on the new ‘salaried member’ rules, the rules that will treat members of an LLP as employees for tax purposes in certain circumstances.
House Ways and Means Committee chairman Dave Camp this week introduced a draft of the most comprehensive reform of the Internal Revenue Code in decades.
Spain’s Basque Country extends participation exemption regime to capital gains on transfer of shares in Spanish companies download
Spain’s autonomous Basque Country region has extended its participation exemption regime to capital gains derived from the transfer of shares in Spanish companies
A Brazilian newspaper has reported that the Internal Revenue Service is preparing regulations to require foreign web-based companies to invoice locally and pay local taxes.
Tax Guide 2014–15 — South Africa download
This guide details the thresholds for a variety of taxes, both personal and business, in South Africa from 1 March 2014 onwards.
Two years on from DLA Piper’s report The Trust Deficit: Views from the Boardroom, the firm returns to the theme and asks how companies can foster a culture of trust in a post-crash economy.
Camp unveils major tax reform plan download
House Ways and Means committee chairman Dave Camp has unveiled his tax reform proposal, which calls for the most fundamental reform of the tax code in 27 years.
New LLP tax rules download
HMRC has published updated guidance on the new ‘salaried member’ rules — the rules that will treat members of an LLP as an employee for tax purposes in certain circumstances.
Nabarro partners are to vote in March on a cash call to its fixed-share partners in order to meet new tax rules for LLPs handed down by the HMRC.
Decision on whether receivers and liquidators must withhold tax in absence of an assessment download
Justice Logan of the Federal Court has handed down the much anticipated decision in Australian Building Systems Pty Ltd v Commissioner of Taxation.
This guide is a summary of the law and procedures relating to limited partnerships in Guernsey.
In his state-of-the-nation address in December 2013, the Russian president stressed the need for urgent measures to ‘de-offshorise’ the economy.
Hill Dickinson is consulting on its second cash call in 12 months in response to HM Revenue & Customs’ (HMRC) change to the partnership taxation rules, which will come into effect on 6 April.
Eversheds’ James Batham has said that the British Retail Consortium’s recommendations for overhauling business rates will be welcomed by retailers.
Giles Salmond has said that countries such as Luxembourg are likely to lose out when EU rules on VAT on e-commerce transactions come into force in 2015.
The London office of Baker Botts is launching a new flexible resourcing initiative that will see it hire lawyers, potentially on a full-time self-employed consultancy basis, to fill a range of areas it currently sub-contracts out to UK firms.
California has replaced the Enterprise Zone Hiring Credit with the New Employment Credit and the California Competes Credit.
This article explores profit and loss allocations by partnerships, the special rules for AIFMs and the disposal of assets through partnerships that lead to a tax advantage.
The Committee of Fiscal Affairs of the OECD has released its proposed updated guidelines on transfer pricing documentation.
Luxembourg has entered into 68 comprehensive double tax treaties based on the OECD model tax convention on income and capital.
Eversheds has commented on the recent cut in UK business rates by communities secretary Eric Pickles.
New tax rules for LLP members download
The government has issued draft anti-avoidance legislation that overrides the current presumption that a member of an LLP is self-employed for tax purposes and is not an employee.
Tax Update — January 2014 download
In this Tax Update, Arendt & Medernach focuses on both Luxembourg and international news.
The old saw about the best-laid plans of mice and men also goes for international tax planning and transactions with significant tax consequences.
Domestic double taxation relief applicable to capital gains derived by EU resident entities on disposal of shares in Spanish entities download
The Supreme Court has stated that, under EU regulations, the denial of the deduction for non-resident entities is contrary to the principle of free movement of capitals.
Executive share plans: guide to executive share plans to motivate a broad range of employees download
This guide highlights the variety of share plans in the market and illustrates the way in which these can be tailored to meet specific requirements as needed.
Tax support for the UK onshore shale gas industry: an innovative approach to an unconventional fuel reserve download
The government is ambitious to support industry in its exploitation of shale gas as a new source of energy supply.
The deadline for HMRC’s new partnership tax rules is closing in. Is it too late for firms to plan a safe way through?
The passenger of a hot air balloon that is losing altitude is advised to throw out as much luggage as possible. This appears to have been the thought of HMRC in the litigation against Skyview Ballooning.
HM Revenue & Customs has proposed to tighten up the rules allowing members of a limited liability partnership to be treated as self employed.
Law à la Mode — 2013–14 download
DLA Piper has published the winter edition of Law à la Mode, which includes a review of the potential pitfalls and opportunities when franchising in the UAE.
The crucial point about these proposed changes is that they will apply to all EMI options, not just those granted from the dates that the changes have effect.
HMRC salaried partner changes send shockwaves through LLPs
Mills & Reeve has merged with George Davies Solicitors, increasing its national insolvency and recovery team by 50 per cent.
HM Revenue & Customs (HMRC) has published its “dramatic” proposals for changes to the partnership tax regime, a move aimed at dealing with the so-called ‘disguised salary’ of LLP members that looks set to create upheaval in finance teams across the UK.
Chancellor George Osborne has delivered a fiscally neutral Autumn Statement, which was a ‘long-term plan for a grown-up country’.
Autumn Statement 2013: tax summary download
This briefing contains a summary of the main tax points of interest with draft legislation enacting the proposed changes to be published on 10 December 2013.
Autumn Statement 2013 download
Following the release of the Autumn Statement, Taylor Wessing has summarised some of the main announcements.
Allen & Overy tax partner Lydia Challen has written an article for British Tax Review as part of its analysis of the Finance Act 2013 provisions.
In this briefing, DLA Piper sets out a summary of key items of interest announced by the chancellor in the UK Autumn Statement.
Philip Myers of Eversheds has commented in response to the UK chancellor’s announcement that the rise in business rates will be limited to two per cent.
A recent case has underlined the importance of a regular review of founding documents to ensure that those documents continue to meet your not-for-profit organisation’s objectives.
This is the second of two looks at new measures being introduced by the Revenue to crack down on what it perceives as the use of partnerships for tax avoidance purposes.
Tax investigations lawyers have the skills to unpick fraud cases - just ask Al Capone
This guide provides readers with an overview of Australia’s business rules, from foreign investment guidelines to taxation, consumer protection, intellectual property and the employment law system.
The Revenue has announced a number of measures to crack down on what it perceives as the use of partnerships for tax avoidance purposes.
The curious case of Manches’ suicidal cashflow management and its eleventh-hour rescue by Penningtons
The ATED tax, effective from April 2013, applies to companies (and similar kinds of structures) that own dwellings with an individual value of £2m upwards.
Doing Business in Japan download
DLA Piper is pleased to announce the launch of the first edition of its Doing Business in Japan publication.
On 25 September 2013, the French government released the key measures of the draft Finance Bill for 2014 that would have a notable impact on French companies.
Corporate debt download
HMRC launched a consultation in June 2013 on modernising the taxation of corporate debt and derivative contracts.
Employee shareholder status download
As from 1 September 2013, companies are now able to enter into employee shareholder agreements with employees.
GAAR: the general anti-abuse rule download
On 17 July 2013, the UK introduced a new general anti-abuse rule (GAAR).
The French Parliament intends to strengthen the transfer pricing documentation requirements.
On 21 August 2013, the French Ministry of Finance updated the so-called ‘black list’ for 2013 (the list of non-co-operative countries or territories).
On 25 September 2013, the French government released the key measures of the draft Finance Bill for 2014 that would notably affect French companies.
Ben Jones, tax expert at Eversheds, commented after the EU launched a probe into Gibraltar’s corporate tax regime.
Hogan Lovells has hired a senior transfer pricing specialist from turnaround business Alvarez & Marsal in its London corporate tax team.
Minter Ellison’s national tax team provides clients with innovative tax structuring and advisory services that are independent and cost effective.
Tax experts in Switzerland now predict that certain Swiss tax regimes will ultimately need to be repealed.
The Coalition announced before the election that it will undertake a major reform of the not-for-profit sector.
No duty to avoid tax. No kidding download
The Tax Justice Network has received a legal opinion from Farrer & Co. It basically concludes that there is no positive duty on directors to avoid tax.
DLA Piper has welcomed the recently introduced Direct Investment Promotion Law in the State of Kuwait (Decree Law No. 116 for 2013).
Governor Rick Perry has signed into law Texas HB 500, which provides for certain changes to the Texas franchise tax provisions.
Form 42 — are you ready? download
Now that the tax year 2012/2013 has ended, companies must ensure they fulfill their reporting requirements by completing a Form 42 in respect of any share transactions involving employees that have taken place during the tax year.
Companies carrying out R&D-related activities and incurring general day-to-day running costs may be able to reduce their corporation tax liability by claiming relief under the R&D tax relief scheme.
Limited liability partnerships in Jersey are a statutory form of vehicle, established under the Limited Liability Partnerships (Jersey) Law 1997, that have a number of special characteristics.
If it is implemented as proposed, the financial transaction tax is likely to cause distortion to the financial sector and will almost certainly change the way we do business.
Taxation is one of Dacheng’s traditional fields of expertise and one that the law firm is particularly adept at handling in today’s ever-changing and complex commercial environment.
US Senate Finance Committee white paper — signal of international corporate tax reforms to come? download
The US Senate Finance Committee has released its white paper on international competitiveness.
Tax — recent news highlights download
The Serbian government has decided to further amend the law on personal income tax and the law on property tax.
Taylor Wessing has set out a summary of some of the main announcements of the 2013 Budget.
DLA Piper has released a summary of all of the firm’s rankings and editorial commentary in Chambers Global 2013.
Budget 2013: tax summary download
This briefing from Shoosmiths provides a summary of the main tax points of interest with the draft Finance Bill to be published on 28 March.
Congress finally got around to extending the production tax credits and investment tax credits for wind, geothemal, biomass, marine, landfill gas and hydro projects.
Fashion: Law a la mode Autumn 2012 download
Legal issues in the fashion industry, including strategies against copyright infringement and counterfeiting, as well as an overview of recent controvewrsies concerning transfer pricing.
In the Budget, the Chancellor stuck to his promise to come down like a “tonne of bricks” on wealthy individuals who are seen as not paying their fair share of SDLT by buying valuable residential property in corporate vehicles and eventually selling the shares in those corporate vehicles free of SDLT.
An overview of developments in tax law in Montenegro and Serbia.
An overview of developments in tax law in Serbia.
Our Tax Law practice assists national and multinational corporations, industrialists and financial institutions, fund promoters, sponsors and investors in private equity and real-estate transactions.
The Curtis tax group offers clients vast experience in providing advice on the tax aspects of US and international transactions.
New UK property taxation rules download
The UK government announced proposals in its 2012 Budget to introduce new tax charges for high-value residential properties and for properties owned by ‘non-natural persons’.
HM Revenue & Customs on 14 January published new guidelines (INTM120085) on non-standard treaty tiebreakers that could have an impact on the UK’s tax treaties with the United States, Canada, and the Netherlands.
Tax is an essential focal point for any business. It has the potential to impact on all aspects of day-to-day operations, from meeting compliance obligations to undertaking bespoke planning for a complex capital reorganisation.
The firm’s expertise in all aspects of corporate and commercial law gives it a unique ability to understand both the key legal and tax-related issues when providing taxation advice.
The draft Finance Bill published last week includes a number of provisions and changes in respect of the taxation of residential properties valued over £2 million (so called “high value” residential properties) which are acquired and owned by companies and certain other nonnatural persons.
Following the consultation process carried out over the summer months, the Government has confirmed that new tax reliefs for the creative sector – intended to be “the most generous available in the world” - are due to be introduced as part of the Finance Act 2013.
SEIS and EIS: Time for reflection download
From 6 April 2012, the Seed Enterprise Investment Scheme (SEIS) was introduced enabling certain individual investors to benefit from generous tax reliefs for investing into start up companies.
The Patent Box download
The UK Government has been keen to improve the UK’s competitiveness in the high-tech arena. This was largely motivated by a string of departures of UK headquartered multinationals from the UK.
On January 17, 2013, the Internal Revenue Service (IRS) released 544 pages of final regulations implementing the provisions of the Foreign Account Tax Compliance Act (FATCA).
UK implementation of FATCA download
The US government enacted the Foreign Account Tax Compliance Act (“FATCA”) on 18 March 2010. FATCA generally imposes significant due diligence, information reporting and control burdens on a range of non-US financial intermediaries and investment entities.
An introduction to the tax laws surrounding capital call subscription credit facilities.
UK property investment can be highly attractive for overseas investors.
The Advocat General (AG) has opined that investment advice provided to an investment fund constituted an activity of management and therefore benefitted from VAT exemption.
Following the case of Robinson Family Ltd v HMRC, HM Revenue & Customs have been forced to retreat from their long standing position that the grant of an overriding lease does not amount to a transfer of a going concern.
On 8 October 2012, the Chancellor of the Exchequer announced plans for the introduction of a new form of employment relationship – the “employee-owner”.
Tax: Employee share plans download
For both listed and unlisted companies, employee share plans can play a crucial role in the recruitment and retention of employees at all levels within their business, especially since some forms of employee share plan attract tax favourable treatment in the UK.
Momentum is building to reform the US tax system and address the nation’s fiscal challenges.
From 1 April 2013, UK companies will be able to elect into a new regime that applies a lower rate of corporation tax to profits from qualifying intellectual property rights.
French draft budget for 2013 download
On 28 September 2012, the French government released its much-awaited draft budget for 2013, which, unsurprisingly, contains significant tax increases, targeting wealthy individuals and large businesses.
Recommendations of the expert committee on the Indian General Anti-Avoidance Rule: a welcome step download
On 1 September 2012, the Shome Committee, which was constituted by Indian Prime Minister Manmohan Singh to review the General Anti-Avoidance Rule, submitted its 108-page Expert Committee Report to the Indian Government.
The US and the UK announced on 14 September that they have signed a bilateral agreement to improve international tax compliance and implement the information reporting and withholding tax provisions of the Foreign Account Tax Compliance Act (FATCA).
The world of international taxation becomes more transparent with every passing year.
?Greenberg Traurig Maher (GTM) has hired Paul Hastings Janofsky & Walker’s London vice-chairman to bulk up its tax practice in the City. Justin Hamer is the seventh partner to join the US firm in London since it launched in June. GTM launched with Mayer Brown co-vice-chair Paul Maher. Maher was joined by Mayer Brown partners Fiona Adams and Cate Sharp before hiring a capital markets trio from White ...
Freshfields Bruckhaus Deringer has secured a gagging order against The Guardian on behalf of Barclays Bank, forcing the newspaper to remove some of the bank’s internal documents from its website.