Category: 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
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
Spain’s National Court challenges the deductibility of intragroup services in the absence of a written contract
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
Austria updates transfer pricing guidelines
An update on Austrian transfer pricing rules was made on the 7th October 2021. Details are here. ... - Continue reading
Russia submits a proposal to revise the DTT with Switzerland
The Russian Ministry of Finance has sent a proposal to its Swiss colleagues requesting amendments to the current double taxation treaty (DTT) between Russia and Switzerland ... - Continue reading
How to help clients as HMRC cracks down on overseas assets
‘International data sharing and anti-money laundering regulations are only likely to get tighter’ ... - Continue reading
