Category: Regulatory

Beneficial Ownership / Debt / Dividends / Interest and Royalties Directive / Parent-Subsidiary Directive / Regulatory / Tax Exempt / Withholding Tax

Italy’s Supreme Court resolves withholding tax dispute over interest paid to holding company

Published by: MNE Tax - September 10, 2020

The Italian Supreme Court, in a decision released 10 July, has addressed whether a sub-holding company was beneficial owner of interest payments for withholding tax purposes, applying the European Court of Justice’s holdings in the well-known Danish cases. ... - Continue reading

Business / Tax Authority / Tax Avoidance / Tax Evasion / United Kingdom

HMRC says 10% rise in UK tax evasion reports is due to whistleblowers

Posted On: September 1, 2020

HMRC, the British government’s tax authority, has reported a 10% rise YoY in evasion probes – and says the increase is due to a surge in whistleblowers. Today’s figures, released by UHY Hacker Young, reveal 73,000 reports arising from whistleblowing, representing a 10% rise on the numbers for 2018-19.UHY Hacker… – Continue reading

Arbitration / Arbitration Act / Bermuda / Debt / Immovable Property / Infrastructure / Interest / Legislation / Offshore / Offshore Trusts

Bermuda: Enforcement Of Judgments 2020 – Trends And Developments

Published by: Mondaq - September 1, 2020

Bermuda is a self-governing overseas territory of the United Kingdom. It has a population of over 60,000 people on a land mass of just 21 square miles. The island group is located in the Atlantic Ocean, approximately 760 miles due east of Cape Hatteras, North Carolina. Surrounded by coral reefs and the Gulf Stream, Bermuda remains a popular destination for tourists but its infrastructure, flexible and innovative corporate structures and strong regulatory environment have made it a leading offshore jurisdiction for company incorporations, including for a number of companies listed on the main New York and Hong Kong stock exchanges ... - Continue reading

Business / Jurisdiction / Multinationals / OECD / Philippines / Profit Shifting / Related party Transactions / Tax Collection / Transfer pricing

Enhanced transfer pricing regime amidst the pandemic

Posted On: August 31, 2020

Globally, the coronavirus disease 2019 (Covid-19) pandemic is requiring governments to design and implement strategies to cope with the deepening impact of the virus. They are introducing measures to cushion the blow from the economic downturn, such as drawing from reserves and intensifying tax collection efforts. As entire countries and… – Continue reading

China / Double Taxation Agreement / Hong Kong / Serbia

China’s Hong Kong, Serbia sign comprehensive avoidance of double taxation agreement

Posted On: August 28, 2020

HONG KONG, Aug. 28 (Xinhua) — The government of China’s Hong Kong Special Administrative Region has signed a comprehensive avoidance of double taxation agreement (CDTA) with Serbia, signifying the government’s sustained efforts in expanding Hong Kong’s tax treaty network, a government spokesman said Friday. The CDTA is the 44th such… – Continue reading

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