Category: Government Bodies

Canada Revenue Agency / Capital gains / Capital Gains Tax / Double Tax Treaty / Income Tax Act / Legislation / Tax Avoidance / Tax Laws / Tax Planning

Canada: “Changing Of The GAAR”: A Background On The General Anti-Avoidance Rule, And Canada’s Attempt To Expand Its Tax Power In The 2022 Budget

Published by: Mondaq - April 29, 2022

The Budget purports to introduce several new financial and taxation regimes, as well as enhance several existing mechanisms. One of the existing taxation mechanisms proposed to be amended is the General Anti-Avoidance Rule (the "GAAR"). The Government initially indicated they would be amending the GAAR in the 2021 Budget. The 2022 Budget now provides some additional detail, though we are still waiting for the actual legislation. ... - Continue reading

Business / Compliant / Framework / OECD / Permanent establishment / Tax Credit

 The Pillar Two model rules: a train wreck in the making

Published by: MNE Tax - March 10, 2022

On December 20, 2021, the OECD issued model rules for Pillar Two—the 15% global minimum tax. It is a brutally complex 70-page package and introduces two fundamental changes to the October 2021 OECD framework: a new Qualified Domestic Minimum Top-Up tax (QDMTT) and a significant rewrite of the Undertaxed Payment Rule (UTPR). ... - Continue reading

Automatic Exchange of Information / Bilateral Agreement / Certification / FATCA / Financial Institutions / OECD / Private Equity Funds / Tax Authority / Tax Avoidance / Tax Evasion / Withholding Tax

Q&A: tax issues for private equity funds in Cayman Islands

Published by: Lexology - March 10, 2022

Under current Cayman Islands law, there are no Cayman Islands taxes on income or gains of the private equity fund (PE fund) or on gains on dispositions of shares or partnership interests, and distributions made by a PE fund will not be subject to withholding tax in the Cayman Islands. ... - Continue reading

Business / Corporate Tax / Intragroup Services / Legislation / OECD / Tax Deductibility / Tax Planning / Transfer pricing

Spain’s National Court challenges the deductibility of intragroup services in the absence of a written contract

Published by: MNE Tax - March 9, 2022

In recent years, the Spanish tax administration and Spanish courts have had a clear tendency to challenge the provision of intragroup services, denying its corporate income tax deductibility and increasing the tax burden for taxpayers carrying out these transactions in Spain. ... - Continue reading

Follow:

Trending Now

Top 10 Sources