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Documents on Taxation, Banking & Financial Services
 

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HTMLEurasian Economic Union
Victoria Simonova; Dentons Canada LLP;
Legal Alert/Article
November 17, 2014, previously published on October 8, 2014
On 29 May 2014, the presidents of Kazakhstan, Russia and Belarus signed an agreement (the "Treaty") in Astana on the Eurasian Economic Union (the "EaEU" or the "Union"). The Treaty will enter force on 1 January 2015. According to the Treaty, the Union is an...

 

HTMLNew Provisions Concerning Thin Capitalization in Poland
BSJP Brockhuis Jurczak Prusak Sp.k.;
Legal Alert/Article
October 31, 2014
On the 1st January 2015 the provisions regarding tax deduction of the interest paid for the loans provided by the related companies (thin capitalization) are about to change.

 

HTMLCanadian Back-to-Back Loan Proposals
Nigel P.J. Johnston, Gabrielle M.R. Richards; McCarthy Tétrault LLP;
Legal Alert/Article
October 22, 2014, previously published on October 15, 2014
The 2014 federal budget included measures (Budget Measures) intended to eliminate the use of back-to-back loans to avoid the thin capitalization rules and/or withholding tax on interest paid to non-arm’s length non-residents so as to protect the Canadian tax base from erosion by limiting the...

 

Adobe PDFVAT Groups: Potential VAT Costs for Financial Groups as ECJ Recognises Intra-Entity Supplies between US Head Office and VAT-Grouped Branch
Sullivan Cromwell LLP;
Legal Alert/Article
October 19, 2014, previously published on October 10, 2014
The European Court of Justice has decided that IT services provided by Skandia America Corporation to its Swedish branch should be recognised for VAT purposes because the Swedish branch was part of a VAT group.

 

HTMLRepeal of the Interest-Withholding Tax on Certain Cross-Border Loans
Jones Day;
Legal Alert/Article
October 16, 2014, previously published on October 2014
As a rule, if a nonresident lender grants a loan to an Italian resident borrower, the interest paid on the loan is subject to a 26 percent withholding tax in Italy unless the lender is eligible for the exemption under the Italian laws that implemented the EU Interest and Royalties Directive. The...

 

HTMLTax Evasion: Number of Amended Tax Returns Has Doubled
Andreas P. Demetriades; Andreas P. Demetriades & Associates- Advocates,Legal and Tax Consultants - Law Firm;
Legal Alert/Article
October 8, 2014
Cyprus: The three most popular types of International Business Companies (IBCs) operating through Cyprus: Financing, Holding and Trading Companies.

 

HTMLForeign Asset Disclosure, Financial Reporting and Tax Planning in a Complex World
Alison V. Lennarz; Kaufman & Canoles A Professional Corporation;
Legal Alert/Article
September 11, 2014
Globalization, and the interwoven economies of countries around the world that result from it, is only gaining momentum. Increasingly sophisticated communications and transportation technologies and services, mass migration and the movement of peoples, a level of economic activity that has outgrown...

 

HTMLNon-Dischargeable Tax Debt Not Special Class of Unsecured Creditors
Scott St. Amand, J. Ellsworth Summers; Rogers Towers, P.A.;
Legal Alert/Article
August 28, 2014, previously published on August 26, 2014
In numerous previous posts, we have noted that the purpose of the Bankruptcy Code is to help the “honest but unfortunate debtor.” Like gerrymandering, certain “creative” debtors have attempted to classify their non-dischargeable debt as a separate, special class of unsecured...

 

Adobe PDFChile and the United States Sign the Inter-Governmental Agreement ("IGA") Within the Scope of the Foreign Account Tax Compliance Act ("FATCA")
Diego Peralta, Jessica Power, Elena Yubero; Carey;
Legal Alert/Article
August 15, 2014
FATCA is a United States Act that requires US persons, including individuals who live outside the United States, to report their financial accounts held outside of the US, and requires foreign financial institutions ("FFIs") to report information regarding their US clients to the US...

 

HTMLNew Tax Rules for Loans Taken Out By UK Resident Non-Domiciliaries
Withers Bergman LLP/Withers LLP;
Legal Alert/Article
August 6, 2014, previously published on August 5, 2014
With effect from 4 August 2014, HMRC have changed, without notice, their stated position with respect to the treatment of commercial loans to UK resident and non-domiciled individuals. Action is required if individuals wish to avoid paying additional tax as a result of their existing arrangements.

 


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