May 2015
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    • Businesses report difficulties in obtaining APAs with China
      Though China has had an advance pricing agreement (APA) programme for nearly a decade, some businesses report that obtaining APAs in China is challenging due to a lack of manpower at the State Administration of Taxation’s (SAT) transfer pricing team.
    • Implementing the BEPS Action Plan in Mexican domestic law
      One of the concerns that has arisen for governments around the world is the erosion of the national tax base caused by a globalised economy, the progress of technology and the development of telecommunications. Ricardo Rendón and César de la Parra of Chevez, Ruiz, Zamarripa y Cía look at the Mexican perspective on base erosion […]
    • The Brockman brief: UK diverted profits tax: The extrapolation effect
      The UK’s diverted profits tax (DPT) was developed, and enacted, quickly in the weeks leading to the general election. The legislation was a two-pronged attack: on transactions having insufficient economic substance and the avoidance of permanent establishment (PE). The legislation went into effect April 1 2015 and there have been hints that other countries are […]
    • Canada tax law
      Taxman LetterBomb taxes taxman "tax problem" "CRA problem" DioGuardi "DioGuardi tax" "tax law" "canada tax law" "canada tax problem" "tax amnesty" "canada tax amnesty" …
    • Legal tax shelters
      How John LaBruzzo Wants To End Welfare Abuse www.corrupt.org How can we get more people who rely on government to have fewer children who rely on government? This was the question John …
    • ECJ clarifies German case on investment fund lump-sum taxation
      In its judgment dated May 21 2015 (Wagner-Raith) the European Court of Justice (ECJ) confirmed that the German lump-sum taxation according to section 18 paragraph 3 of the German Foreign Investment Act (GFIA), as effective until the end of 2003, is within the scope of the standstill clause of article 57, EC Treaty.
    • The Brockman brief: UK diverted profits tax: The extrapolation effect
      The UK’s diverted profits tax (DPT) was developed, and enacted, quickly in the weeks leading to the general election. The legislation was a two-pronged attack: on transactions having insufficient economic substance and the avoidance of permanent establishment (PE). The legislation went into effect April 1 2015 and there have been hints that other countries are […]
    • Substance-over-form in China's GAAR
      Scott Heidecke and Flora Luo of Nexia International member firm Nexia TS (Shanghai) discuss China's latest attempts to implement countrywide standard practices for application of the general anti-avoidance rules, while bringing clarity to foreign entities which are affected.

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