Google has since last year been collecting tax information related to the US earnings of Taiwanese YouTubers and withholding the share of their proceeds that they owe in taxes, complying with a US government directive. In contrast, Taipei has not been able to tax the online advertising revenue Google generates in Taiwan. ... - Continue reading
On 7 June 2022, a new Double Tax Treaty (the “DTT”) has been signed between Luxembourg and the United Kingdom (UK) to reflect the most recent OECD tax standard. ... - Continue reading
As governments look for ways to recoup pandemic spending, tax transparency takes on a new level of significance. ... - Continue reading
Financing structures involving Irish entities often employ the use of a special-purpose vehicle ("SPV"), which is a company established specifically to hold title to the aircraft subject to the financing and to lease those aircraft to the operators. Ireland is a popular jurisdiction for the establishment of SPVs due to the numerous double-tax treaties in place between Ireland and other countries, many of which specifically refer to aviation in their text. Ireland is also attractive due to the confidence in the legal and court system (which is broadly based on English common law) and the number of aviation experts and leasing companies based in Ireland. ... - Continue reading
The global minimum corporate tax on MNCs was aimed at discouraging them from shifting profits to low-tax countries. But it will reduce the incentives to attract investment in developing countries ... - Continue reading
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
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
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
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
An update on Austrian transfer pricing rules was made on the 7th October 2021. Details are here. ... - Continue reading
More than 130 countries agreed on Friday to rolling out historic changes to international tax rules, after leaders agreed to a new global minimum tax rate of 15 per cent targeted at companies with annual revenue of more than 750 million euros. ... - Continue reading
