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HTMLTreasury Department and IRS Issue Long-Awaited Inversion Guidance
Jones Day;
Legal Alert/Article
October 16, 2014, previously published on October 2014
On September 22, 2014, the U.S. Treasury Department and the IRS issued long-awaited inversion guidance in the form of Notice 2014-52. The Notice sets forth rules that are generally effective for transactions completed on or after September 22, 2014, and will be included in regulations that will be...

 

HTMLTax Rules Included in the Mexican Energy Reform
Jones Day;
Legal Alert/Article
October 16, 2014, previously published on October 2014
On August 6, 2014, the Mexican Congress approved some of the secondary legislation related to the so-called Mexican Energy Reform. The approved laws were published in the Mexican Official Gazette on August 11, 2014. Among the approved secondary legislation is the Hydrocarbons Revenues Law, which...

 

HTMLDutch Innovation Box Regime for Intangibles is Clarified in Decree
Jones Day;
Legal Alert/Article
October 16, 2014, previously published on October 2014
The Innovation Box was introduced in 2007 to encourage companies to innovate and increase their research and development ("R&D"). Under this optional regime, subject to certain conditions, Dutch corporate taxpayers are taxed at an effective rate of 5 percent. In the newly published...

 

HTMLJudgment of Tokyo District Court: Application of a General Anti-Avoidance Rule Concerning Reorganization Transactions
Jones Day;
Legal Alert/Article
October 16, 2014, previously published on October 2014
On March 18, 2014, the Tokyo District Court affirmed corporate tax assessments against two tax payers: Yahoo Japan Corporation ("Yahoo Japan"), a Tokyo Stock Exchange listed company, and IDC Frontier Inc. ("IDCF"), a wholly owned subsidiary of Yahoo Japan.

 

HTMLSDLT and Property Investment Funds
Jones Day;
Legal Alert/Article
October 16, 2014, previously published on October 2014
The UK government has announced that it will be looking at whether any changes are needed to current stamp duty land tax ("SDLT") rules to cater for two specific forms of collective investment scheme designed for investors in the UK market.

 

HTMLOECD Releases First BEPS Recommendations to G20 in Accordance with Action Plan
Jones Day;
Legal Alert/Article
October 16, 2014, previously published on October 2014
As a part of the OECD/G20 project to combat base erosion and profit shifting ("BEPS"), the OECD released the first set of reports and recommendations on September 16, 2014.

 

HTMLWithholding Tax Exemption on Bond Interest Broadened
Jones Day;
Legal Alert/Article
October 16, 2014, previously published on October 2014
Law Decree No. 91 of June 24, 2014, converted into law by the Italian Parliament on August 7, 2014, has broadened the scope of the withholding tax exemption applicable to eligible nonresident investors (i.e., investors resident in a white-listed country and with no permanent establishment in Italy)...

 

HTMLFurther Reference to CJEU on Card Handling Charges
Jones Day;
Legal Alert/Article
October 16, 2014, previously published on October 2014
The First Tier Tax Tribunal has referred certain questions regarding the liability for VAT of card handling charges to the Court of Justice of the European Union ("CJEU") in the case of Bookit Ltd v The Commissioners For Her Majesty's Revenue & Customs.

 

HTMLDraft Guidance for the General Anti-Avoidance Rule
Jones Day;
Legal Alert/Article
October 16, 2014, previously published on October 2014
On July 3, 2014, the State Administration of Taxation (the "SAT") released a discussion draft on the Administrative Measures on the General Anti-Avoidance Rule (the "Draft Measures). The General Anti-Avoidance Rule ("GAAR") was introduced in China Corporate Income Tax Law...

 

HTMLTax Evasion: Risk of Discovery Increases - Amended Tax Return as a Way Out
Michael Rainer, Michael Rainer; GRP Rainer LLP;
Legal Alert/Article
October 16, 2014, previously published on October 14, 2014
It is becoming increasingly difficult for tax evaders to remain undetected due to the automatic exchange of information between EU member states, particularly as Switzerland has signalled its willingness to cooperate.

 


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