1 Chapter Avbreht, Zajc & Partners Ltd. Ursula Smuk 1 General: Treaties 1.1 How many income tax treaties are currently in force in? 44 income tax treaties are currently in force in. 1.2 Do they generally follow the OECD or another model? Although only acceded to the OECD in 2010, the treaties currently in force generally follow the OECD model, with the exception of those concluded by Yugoslavia with Cyprus and Sweden. The latter, which are applicable to by way of succession, are the only two remaining bilateral income tax treaties, which have not as yet been renegotiated. 1.3 Do treaties have to be incorporated into domestic law before they take effect? In order for a treaty to take legal effect in, it must be ratified by the Slovene Parliament and published in the Official Gazette. 1.4 Do they generally incorporate anti-treaty shopping rules (or limitation of benefits articles)? Apart from some notable exceptions, such as the treaty with the United States and Malta, the relevant tax treaties generally do not incorporate specific limitation of benefits provisions. 1.5 Are treaties overridden by any rules of domestic law (whether existing when the treaty takes effect or introduced subsequently)? Pursuant to the provisions of the Constitution of the Republic of, all domestic laws and rules must comply with the general principals of international law and treaties, to which has acceded. From this it may be derived that treaties generally may not be overridden by domestic law. 2 Transaction Taxes 2.1 Are there any documentary taxes in? There are currently no documentary taxes in. 2.2 Do you have Value Added Tax (or a similar tax)? If so, at what rate or rates? has Value Added Tax at the standard rate of 20%. A reduced rate of 8.5% applies to items which are specifically enumerated in the Slovene VAT Act. These items include, but are not limited to food, medicine and medical equipment, and some residential buildings. 2.3 Is VAT (or any similar tax) charged on all transactions or are there any relevant exclusions? Slovene VAT regulations closely follow Directive 2006/112/EC, which gives Member States a certain degree of leeway regarding exclusions / exemptions. In general, the supply of goods and services as well as the import of goods and the Intra Community acquisition of goods, are subject to VAT. Several exclusions are, however, provided for in the Slovene VAT Act, which include but are certainly not limited to the sale of shares in a company, an active trade or business and the sale of securities. The sale of certain (used) real estate is also VATexempt unless the parties opt to treat the supply as a taxable transaction (in which case the standard rate of 20% applies). 2.4 Is it always fully recoverable by all businesses? If not, what are the relevant restrictions? Taxable persons are generally entitled to deduct input VAT, insofar as the VAT is incurred in the provision of the business own taxable transactions. Taxpayers rendering VAT-exempt services however, such as banking and financial services, are not entitled to deduct input VAT. Additionally, it may be noted that not all businesses are required to register for VAT purposes - namely businesses with an annual turnover of under 25,000 EUR are not obligated to register for VAT purposes. 2.5 Are there any other transaction taxes? The transfer of real property for consideration is subject to a real estate transaction tax. The tax rate of this transfer tax is 2% and the taxable basis is the purchase price of the immovable property. If the purchase price is at least 20% lower than the estimated real market value of the property, 80% of the market value shall be considered as the taxable basis. It is important to note that the Real Property Transaction Act specifically states that for the purpose of the taxation of the relevant transaction, transfer of title of property, for which VAT has already been charged, is not subject to real estate transaction tax.
2 2.6 Are there any other indirect taxes of which we should be aware? Goods imported from outside the EU are subject to custom duties and excise duties are levied on particular classes of goods (e.g. tobacco, alcohol and mineral oils). In addition, green taxes can apply to certain limited transactions. 3 Cross-border Payments 3.1 Is any withholding tax imposed on dividends paid by a locally resident company to a non-resident? A 15% withholding tax is levied on dividends paid by a local resident company to a non-resident. The relevant tax may be reduced or eliminated pursuant to an applicable tax treaty and/or pursuant to Slovene provisions implementing the Directive 90/435/EC. Moreover, subject to certain conditions, a withholding tax is not levied on dividends paid to a non-resident pension fund, insurance fund or insurance company. Pursuant to Slovene regulations, which implement the Directive 90/435/EC, dividends paid by a local resident company to a nonresident are not subject to a withholding tax, if the non-resident is an EU resident and holds at least 10% of capital or voting rights in locally resident company. A further condition for such tax relief is a minimum two year holding period and that the recipient company is subject to corporate income tax in its State. 3.2 Would there be any withholding tax on royalties paid by a local company to a non-resident? In the event that a local company pays royalties to a non-resident, a withholding tax of 15% is levied, which may be reduced or eliminated pursuant to an applicable tax treaty and/or pursuant to the Slovene provisions implementing the Directive 2003/49/EC. Under the latter, interest and royalty payments made by resident companies are exempt from withholding tax, provided that the recipient company, which is resident in another EU Member State, is subject to corporate income tax in that State, and is an associated company of the paying company. 3.3 Would there be any withholding tax on interest paid by a local company to a non-resident? A 15% withholding tax is levied on interest paid by a local company to non-residents. This tax rate may be reduced or eliminated pursuant to an applicable tax treaty and/ or the Directive 2003/49/EC. Neither interest paid by resident banks to non-resident banks, nor interest paid by resident banks to non-banking entities other than those resident in non-eu low-tax jurisdictions, is subject to withholding tax. Again, it is important to note that also in the case of interest paid to a non-resident pension, investment or insurance fund, subject to certain conditions, a withholding tax is not levied on interest paid. 3.4 Would relief for interest so paid be restricted by reference to thin capitalisation rules? As a general rule, the Slovene Corporate Income Tax Act limits the tax deductability of interest paid on loans granted by a shareholder or partner, holding at least 25% in the share capital or the voting rights of a taxpayer. Interest paid on such loans is not tax deductible if the loan exceeds five times (in 2011) the value of the shareholder's or partner's share in the capital of the taxpayer. This general limitation does not apply however, if the taxpayer manages to prove that the excess loan could have been obtained from unassociated parties. With regards to the thin capitalisation rules, enjoys a transitional period. This transitional period shall continue until 2012, when the debt-to-equity ration fixed at 4:1 shall apply. 3.5 If so, is there a safe harbour by reference to which tax relief is assured? The so-called safe harbour, by reference to which tax relief is assured, may be indirectly detected in the thin capitalisation rules outlined in question 3.4. In addition a safe harbour may be detected within the transfer pricing rules encompassed in Slovene regulations. Pursuant to the latter, interest payments made pertaining to loans granted by associated entities are tax deductible only to the extent that interest paid does not exceed the officially determined and published interest rate. At this point it is important to note however, that the abovementioned thin capitalisation rules only apply to debt provided by an entity with a 25% or over direct or indirect holding in the n tax resident. In this respect, a loan granted by a sister company in a safe harbour would not fall within the scope of thin capitalisation rules. 3.6 Would any such thin capitalisation rules extend to debt advanced by a third party but guaranteed by a parent company? The thin capitalisation rules would also extend to such loans granted by a third party. 3.7 Are there any restrictions on tax relief for interest payments by a local company to a non-resident in addition to any thin capitalisation rules mentioned in questions above? Interest payments made on loans granted to a Slovene resident company by a resident in a so-called low-tax jurisdiction are not tax deductible. According to the Slovene Corporate Income Tax Act, non-eu Member States with a general nominal tax rate lower than 12.5%, fall within the scope of the definition of a low-tax jurisdiction. The Slovene Ministry of Finance compiles and publishes an official list of low-tax jurisdiction States. At this point it also must be highlighted that also the arm's length principle should be taken into consideration in order for interest payments to associated entities to be fully deductible for tax purposes. 3.8 Does have transfer pricing rules? The Corporate Income Tax Act of and the accompanying rules, incorporate transfer pricing rules, which are based on the OECD guidelines. 4 Tax on Business Operations: General 4.1 What is the headline rate of tax on corporate profits? Since 1 January 2010, a flat corporate income tax rate of 20%
3 applies to all corporations. This tax applies to payments to residents and non-residents. Subject to specific conditions, a reduced 0% corporate income tax rate applies to investment funds, insurance companies, pension funds and venture capital companies, which are taxed in accordance with the Slovene Corporate Income Tax Act. 4.2 When is that tax generally payable? An advance payment tax is generally paid on a monthly basis throughout the tax year. Each monthly advance payment amounts to one-twelfth of the tax liability determined in the tax return of the previous year. The difference between the cumulative advance payments carried out within the relevant tax year, and the tax liability determined in the tax return filed for the respective tax year, must be paid within 30 days from the filing of the tax return. The annual corporate income tax return must be filed within 3 months subsequent to the end of the tax year, which may differ from the calendar year. 4.3 What is the tax base for that tax (profits pursuant to commercial accounts subject to adjustments; other tax base)? In principle, a company s net income, therefore taxable basis, is determined in accordance to Slovene accounting principles and provided for in the company s financial statements. Slovene tax law however, provides for several adjustments for tax purposes, e.g. restrictions on the deduction of certain business expenses. As a general rule, expenses incurred in connection with the company s business activities, which fall within the definition of expenses that are commonly incurred in usual business practice, are tax-deductible. 4.4 If it otherwise differs from the profit shown in commercial accounts, what are the main other differences? As stated above, expenses must be incurred in connection to the company s business activities. Expenses are considered not to be in connection with the company s business if they are not usually incurred in business practice, if they are not necessary for the company s business, or if they are of a private nature. More specific rules apply to the determination of the tax deductibility of expenses in certain cases, e.g. claim write-offs are recognised as deductible expenditures for tax purposes, only if the taxpayer has exercised all available means of collection thereof. Furthermore, another main difference is provided with regards to dividends and capital gains. In general, subject to certain conditions, dividends which are conferred upon a resident Company from a resident or non-resident, are not subject to a corporate income tax at the level of corporate shareholders. This general rule however, does not apply if the dividends are paid by residents of low-tax jurisdictions. 4.5 Are there any tax grouping rules? Do these allow for relief in for losses of overseas subsidiaries? Slovene regulations do not provide for tax grouping rules. 4.6 Is tax imposed at a different rate upon distributed, as opposed to retained, profits? The same tax rate is levied upon both types of profits. 4.7 What other national taxes (excluding those dealt with in Transaction Taxes, above) are there - e.g. property taxes, etc.? The Slovene system of property tax is currently being reformed and the new tax is expected to be implemented as of 1 January Currently, property is taxed by three separate local and/ or national taxes and dues, depending on the circumstances pertaining to each specific case. 4.8 Are there any local taxes not dealt with in answers to other questions? The current property tax, which is applicable both to natural and legal persons, who hold real estate is a local tax. The tax is levied on the property value as determined by law. Property tax is levied at progressive rates, from 0.10% to 1.50%, as set by local municipalities. 5 Capital Gains 5.1 Is there a special set of rules for taxing capital gains and losses? In, there is no separate capital gains tax applicable to businesses. Capital gains are therefore considered as normal business income and are thus subject to corporate income tax. 5.2 If so, is the rate of tax imposed upon capital gains different from the rate imposed upon business profits? Capital gains are generally subject to the corporate income tax at the 20% rate. 5.3 Is there a participation exemption? A participation exemption applies to capital gains or losses attributed to the disposal of qualified capital shares or other qualified participation. For the purpose of the relevant provisions, a qualified participation includes at least an 8% share of the capital or voting rights of the company that is subject to disposal. If the latter condition is met, the Slovene Corporate Income Tax Act provides that only 50% of capital gains or losses, attributed to the disposal of shares, are to be included in a Company s taxable basis. In addition to the qualified participation condition, it is important to note that this rule may not apply if the company, which is subject to disposal, is a resident in a low-tax jurisdiction, nor may it apply if the taxpayer company has not met the minimum six-month holding period requirement, in which it employed at least one employee. Similar to dividends, 5% of related expenses are tax non-deductible. 5.4 Is there any special relief for reinvestment? No specific relief is available for reinvested profits. However, companies can claim a tax deduction amounting to 30% of the amount invested in equipment and intangible assets. The relevant deduction may not exceed EUR 30,000, nor the taxable base. Any unused credit may be carried forward for five tax years. Moreover, companies can also claim a tax deduction for 40% of the amount invested in research and development activities, whether these activities be carried out within the company or outsourced. The tax deduction may not, however, exceed the taxable base of the
4 year in which the investments were carried out. Taxpayers carrying out their business activities in a region where the gross domestic product per capita (GDP per capita) is up to 15% lower than the average national GDP per capita, may claim a tax deduction for 50% of the amount invested in research and development. The amount claimed may increase to 60% of the invested amount, if the GDP per capita in the region where the company s business activities are carried out is more than 15% lower than the respective national average. 6 Branch or Subsidiary? 6.1 What taxes (e.g. capital duty) would be imposed upon the formation of a subsidiary? No taxes or fees, apart from those connected to the registration of the subsidiary, are imposed upon the formation of a subsidiary. 6.2 Are there any other significant taxes or fees that would be incurred by a locally formed subsidiary but not by a branch of a non-resident company? Currently no such taxes or fees apply. 6.3 How would the taxable profits of a local branch be determined? The profits of a branch are subject to corporate income tax, if the branch falls within the definition of a permanent establishment. Should this be the case, the taxable income of the permanent establishment includes all income, which is acquired in or via the permanent establishment. In general, the taxable profit of a permanent establishment shall be determined in accordance with the same rules as those applicable to resident companies. It should also be noted that transfer pricing rules should also be applied when determining the taxable basis of a local branch. 6.4 Would such a branch be subject to a branch profits tax (or other tax limited to branches of non-resident companies)? Slovene regulations do not provide for a branch profits or similar tax applicable to branches. Profits attributable to such permanent establishment are subject to the standard corporate income tax. 6.5 Would a branch benefit from tax treaty provisions, or some of them? Under n tax law, a branch is considered a taxable entity for corporate income tax purposes if it qualifies as a permanent establishment within the meaning of a double taxation treaty. 6.6 Would any withholding tax or other tax be imposed as the result of a remittance of profits by the branch? There is no withholding tax levied on the remittance of profits by the branch to the head office. 7 Anti-avoidance 7.1 How does address the issue of preventing tax avoidance? For example, is there a general antiavoidance rule or a disclosure rule imposing a requirement to disclose avoidance schemes in advance of the company s tax return being submitted? Slovene regulations do not address the issue of preventing tax avoidance as such. However, in general the substance over form rule applies, while in the case of fictitious transactions, the underlying transaction is deemed to be effective from a tax perspective. Moreover, taxable persons are required to disclose certain data, which may affect the perceived risk relating to the taxable person by the tax authorities, in their annual corporate income tax returns. The tax authorities may base their investigation strategies on the submitted information.
5 Ursula Smuk Avbreht, Zajc & Partners Ltd. Šestova 2, 1000 Ljubljana Tel: Fax: URL: Ms. Ursula Smuk, dipl. iur. (University of Ljubljana, 2005) and LL.M (City University of Hong Kong 2006/2007, programme in International Trade Law in Asia), is an associate at Avbreht, Zajc & Partners law firm in Ljubljana, one of the leading corporate law firms in. Before joining Avbreht Zajc & Partners, Ms. Smuk worked as a tax advisor in at a big four auditing firm. Avbreht, Zajc & Partners Ltd. is a full-service law firm providing a broad range of advisory services and legal representation to both national and international clients. The firm's main expertise are in the fields of Corporate and Commercial law, Competition Law and Intellectual property law. The firm has offered complete legal support in numerous stock and asset deals, joint ventures, mergers and acquisitions. Our specialisations are also in the fields of public procurement and public private partnerships, media law and telecommunications / advanced technologies. Today we are one of the larger n law firms with even higher ambitions for the future. We deal with companies from various industries such as banking, petroleum, chemistry and pharmacy, insurance, media, construction, new technologies, automotive and others. In the public sector we advise and represent numerous state-owned companies, local municipalities and governmental agencies. We are members of the Warwick International Legal Network (WLN). Highly reputable, independent law practices work within WLN worldwide. Through our membership in WLN we are in the position to meet the need for international legal advice and the highest level of cross-border advice and representation.
TURKEY CORPORATE TAX (KURUMLAR VERGISI) The basic rate of corporation tax for resident and non-resident companies in Turkey is 20%. Corporations in Turkey can be regarded as either limited or unlimited
Introduction Monaco is a sovereign principality. France is a guarantor of the sovereignty and territorial integrity of Monaco, while Monaco is to conform to French interests. Although the Prince is the
Macau SAR Tax Profile Produced in conjunction with the KPMG Asia Pacific Tax Centre Updated: June 2015 Contents 1 Corporate Income Tax 1 2 Income Tax Treaties for the Avoidance of Double Taxation 5 3 Indirect
Quality tax advice, globally GLOBAL GUIDE TO M&A TAX 2013 EDITION www.taxand.com CYPRUS Cyprus From a Buyer s Perspective 1. What are the main differences among acquisitions made through a share deal versus
DOING BUSINESS IN GERMANY Overview on Taxation March 2015 1. Introduction 1.1. Generally, taxes are administered and enforced by the competent local tax office. These local tax offices administer in particular
December 2013 ENCHANCING PORTUGUESE CORPORATE TAX REGIME The Parliament has approved the Portuguese Corporate Income Tax Reform. This Reform, which follow largely the recommendations of the Reform Commission,
TAXATION OF INTEREST, DIVIDENDS AND CAPITAL GAINS IN CYPRUS LAWS AND DECREES The Income Tax (Amendment) Law of 2005 The Special Contribution for Defence (Amendment) Law of 2004 The Assessment and Collection
www.bakertillyinternational.com International Tax Contact Moscow Andrey Kirillov T: +7 (495) 783 88 00 firstname.lastname@example.org Corporate Income Taxes Resident companies, defined as those which
Bulgaria is a parliamentary republic situated in the heart of the Balkan Peninsula at the south - east part of Europe. It is a member of NATO since 2004 and of the European Union since 2007. The territory
INFORMATION SHEET NO.54 Setting up a Limited Liability Company in Poland December 2008 General The Commercial Companies Code (KSH) regulates all issues related to the establishment, activity and dissolution
Holding companies in Irel David Lawless Paul Moloney Dillon Eustace, Dublin Irel has long been a destination of choice for holding companies because of its low corporation tax rate of 12.5 percent, participation
Country Tax Guide www.bakertillyinternational.com Country Tax Guide Germany Corporate Income Taxes Resident companies, defined as companies which are legally constituted in Germany, or which are legally
MALTA Jurisdictional Guide GENERAL INFORMATION The Republic of Malta is situated in the centre of the Mediterranean, south of Sicily, east of Tunisia and north of Libya. Malta gained its independence from
MALTA: A JURISDICTION OF CHOICE LONDON - September 2012 Doing business from Malta can make a huge difference for your business UHY BUSINESS ADVISORY SERVICES LIMITED Updated September, 2012 An attractive
Taxation The combination of Malta s tax system and its extensive double tax treaty network (over 50) means that, with proper planning and structuring, investors can achieve considerable fiscal efficiency
14. Corporate Tax and Depreciation Corporate income tax is levied on income from the worldwide operations of Czech tax residents and on Czech-source income of Czech tax non-residents. Czech tax residents
Brunei Darussalam Tax Profile Produced in conjunction with the KPMG Asia Pacific Tax Centre Updated: April 2013 Contents 1 Corporate Income Tax 1 2 Income Tax Treaties for the Avoidance of Double Taxation
INTERNATIONAL EXECUTIVE SERVICES Thinking Beyond Borders Tanzania kpmg.com Tanzania Introduction Taxation of individuals under the Income Tax Act 2004 (ITA) is on the basis of both residence and source.
Bartosz Bacia Implementation of the EU tax directives in Poland Since Poland joined the EU on May 1 2004, Polish tax law need to be adapted to the EU Council directives for the member states. The new legal
2016 Tax Guideline for the Czech Republic Legal forms of business Social security & Labor law aspects Overview of taxation system General information about the Czech Republic Location: The Czech Republic
Jurisdictional comparison The Netherlands Luxembourg Cyprus Holding companies CORPORATE/LEGAL Incorporation time and costs Possible in 3 days app. EUR 2,500 Less than a week app. EUR 4,000 Up to 2 weeks
TAXATION The following summary of material Cyprus, US federal income and United Kingdom tax consequences of ownership of the GDRs is based upon laws, regulations, decrees, rulings, income tax conventions
United States Corporate Income Tax Summary SECTION 1: AT A GLANCE CliftonLarsonAllen LLP 222 Main Street, PO Box 1347 Racine, WI 53401 262-637-9351 fax 262-637-0734 www.cliftonlarsonallen.com Corporate
Facts on Taxation in Denmark Updated by Njord Law Firm, December 2015 www.investindk.com Contents Corporate taxation... 2 Tax liability for different corporate forms... 2 Full or limited tax liability...
Worldwide personal tax guide 2013 2014 The Netherlands Local information Tax Authority Website Tax Year Tax Return due date Is joint filing possible Are tax return extensions possible Belastingdienst www.belastingdienst.nl
Private Company: SWEDEN Limited Liability Company [Aktiebolag /AB] Partnership [Handelsbolag / HB] Limited Partnership [Kommanditbolag / KB] Formation and Registration Bank Accounts Professional Administration
70. Switzerland Introduction Switzerland does not have specific transfer pricing regulations but respectively adheres to the Organisation for Economic Co-operation and Development (OECD) Guidelines. As
Sharing its capital within the European Union, Belgium is one of the smaller European countries in terms of size. Nevertheless, Belgium is a very dynamic country with multilingual, multicultural influences.
TRINIDAD AND TOBAGO Introduction TAX PRACTICE GROUP Multi-Jurisdictional Survey TAX DESK BOOK CONTACT INFORMATION Myrna Robinson-Walters M. Hamel-Smith &Co Eleven Albion, Dere and Albion Streets, Port-of-Spain,Trinidad
Briefing Overseas investments by Brazilian corporations Summary In this briefing we look at how the Austrian and Spanish domestic tax regimes for holding companies may be relevant when structuring international
Greece Country Profile EU Tax Centre March 2013 Key factors for efficient cross-border tax planning involving Greece EU Member State Double Tax Treaties With: Albania Estonia Lithuania Serbia Armenia Finland
Argentina boasts many natural resources, qualified human resources and the synergies deriving from our commercial partnership with countries like Brazil make it an attractive country in which to invest.
Saudi Arabia Tax Guide I IMPORTANT DISCLAIMER: No person, entity or corporation should act or rely upon any matter or information as contained or implied within this publication without first obtaining
The Netherlands, with a historically strong economic financial climate, is traditionally an important gateway to Europe. Situated in the western part of the European continent with its world leading Rotterdam
The United Kingdom (UK) continues to be one of the world s leading locations for global investment, being rated again as the most attractive place in Europe for foreign investment. i Also, the World Bank
UNITED KINGDOM LIMITED LIABILITY PARTNERSHIPS Background A United Kingdom Limited Liability Partnership (LLP) has become a very popular vehicle for international commercial activity. This is because the
Hong Kong Country M&A Team Country Leader ~ Nick Dignan Guy Ellis Rod Houng-Lee Anthony Tong Sandy Fung Greg James Louise Leung Nicholas Lui Mergers & Acquisitions Asian Taxation Guide 2008 Hong Kong March
International Tax Spain Tax Alert 2 December 2014 Corporate tax reform enacted Contacts Brian Leonard email@example.com Francisco Martin Barrios firstname.lastname@example.org Elena Blanque email@example.com
CORPORATE INCOME TAX IN BALTICS Corporate Income Tax Rates in Baltics Country Standard rate Decreased rate Transfer of loses to next periods Latvia 15% 11% microenterprises Unlimited Lithuania 15% Estonia
The UK as a holding company location Tax May 2013 kpmg.com A key ambition is to create the most competitive tax system in the G20. As well as lowering tax rates, the Government wants to make the UK the
Worldwide personal tax guide 2013 2014 China Local information Tax Authority Website Tax Year Tax Return due date Is joint filing possible Are tax return extensions possible State Administration of Taxation
KPMG INTERNATIONAL Taxation of Cross-Border Mergers and Acquisitions Panama kpmg.com 2 Panama: Taxation of Cross-Border Mergers and Acquisitions Panama Introduction The signing of several Free Trade Agreements
INVESTING IN INDIA OR THE UNITED STATES OF AMERICA THROUGH THE NETHERLANDS Tax Alert April 2013 i Tel +31 I. (0)88 Introduction 2001300 Cell +31 (0)6 M The Netherlands is an attractive and advantageous
14. Corporate Tax and Depreciation Corporate income tax is levied on income from the worldwide operations of Czech tax residents and on Czech-source income of Czech tax non-residents. Czech tax residents
TAXATION EU compliant yet flexible Malta It is is no an big attractive secret that choice the Insurance for companies. sector a number is facing of an operators increasingly relocating tough to envi- the
Hong Kong (Brenda Chan, Nexia Charles Mar Fan & Co, firstname.lastname@example.org) Reviewed January 2015 I MAIN LEGAL FORMS Legal form Characteristics Partnership and Limited Liability Partnership (LLP) Private
GENERAL TAX ISSUES Income tax represents approximately 70 percent of the total tax revenue of the Australian Federal Government Income tax represents approximately 70 percent of the total tax revenue of
Luxembourg.Tax Regime for Intellectual Property Income December 2009 Table of contents 1. Introduction... 2 2. Qualifying IP rights... 3 3. Tax benefits under the IP regime... 3 4. Conditions to benefit
INFORMATION SHEET No. 126 Malta in International Tax Structuring February 2015 Introduction Malta is a reputable EU business and financial centre with an attractive tax regime and sound legislative framework.
THE FLORES LAW FIRM Attorney and Counselor at Law 9901 IH-10 West, Suite 800 San Antonio, TX 78230 TEL. (210) 340-3800 FAX (210) 340-5200 MEXICO TAXATION GUIDE I. RECOGNIZED MEXICAN BUSINESS ENTITIES A.
Malta: an ideal Holding Company location June 2010 TAX Malta a tried-and-tested holding company location Why Malta is a prime EU holding company location Access to Wide treaty network, the EU Parent-Subsidiary
THE MADEIRA INTERNATIONAL BUSINESS CENTRE MADEIRA COMPANY INFORMATION A GENERAL OVERVIEW The Madeira International Business Centre (MIBC) is an established and important international business hub, wholly
13. Taxation The system of taxation described below is derived from the Czech tax legislation and may be modified by a particular Double Taxation Treaty. The current tax system was introduced in January
Chapter 10 FEDERAL TAXATION OF INTERNATIONAL TRANSACTIONS Daniel Cassidy 1 10.1 INTRODUCTION Foreign companies with U.S. business transactions face various layers of taxation. These include income, sales,
Doing Business in Trinidad and Tobago Introduction This guide has been prepared by Baker Tilly Montano Ramcharitar an independent member of Baker Tilly International. This document is designed to assist
The Expatriate Financial Guide to Germany German Tax Facts Introduction Tax Year Assessment Basis Income Tax Taxation in Germany occurs at a national and municipal level. The Ministry of Finance controls
CHAPTER 15. SUMMARY AND CONCLUSIONS 15. 1. Introduction The main question addressed in this PhD thesis is whether the restrictions placed by Dutch law on deducting interest for corporate income tax purposes
Tax l Accounting l Audit l Advisory Company Formation in Austria When considering an investment abroad thought must be given to taxation of income received as dividends and interest as well as any capital
Turkey is located as a bridge between two continents and in close proximity to Europe, the Middle East and the Caucasus. The proximity to the Balkans and the rest of Europe as well as to the growing emerging
This appendix contains a summary of laws and regulations in respect of taxation and foreign exchange in Hong Kong and the PRC. I. TAXATION IN THE PRC 1. Taxes Applicable to Joint-Stock Limited Companies
News Flash September, 2015 Tax guide for property investment in Hungary Tax guide for property investment in Hungary In our current newsletter we would like to inform you about the most important taxation
GENERAL OVERVIEW OF TAXES, LEVIED IN UKRAINE General information on the tax system of Ukraine For the purposes of further discussion we feel it appropriate to provide first brief overview of the tax system
Costa Rica Introduction A person s liability to Costa Rican income tax is determined by the territoriality principle, in opposition to the method of taxation based on residence status. However, residents
SINGAPORE is commerce, industry, heritage, culture and entertainment all rolled into a little island of slightly over 700 square kilometres with a population of 5.4 million. Here at the crossroads of Asia,
Chapter Pierre Elvinger Elvinger, Hoss & Prussen Dirk Richter 1 General: Treaties 1.1 How many income tax treaties are currently in force in? has agreed to 76 income tax treaties. Currently, 64 of these
Hong Kong Last reviewed: 18 March 2014 A. Companies 1. Resident companies Corporate tax rates 16.5% Tax base territorial Unilateral double taxation relief 2. Non- Corporate tax rates 16.5% on sale of shares
Investment and Doing Business in the Czech Republic 8 Residence permit The matters related to foreigner s stay in the Czech Republic are regulated by the Act No. 326/1999 Coll., Act on Foreigner s Stay
2016 BUDGET TAX GUIDE 1 2 This SARS pocket tax guide has been developed to provide a synopsis of the most important tax, duty and levy related information for 2016/17. INCOME TAX: INDIVIDUALS AND TRUSTS
Taxation The statements set out below are intended only as a general guide to United Kingdom ( UK ) and South Africa ( SA ) current law and practice and apply only to certain categories of person who are
TAX GUIDE BELGIUM DISCLAIMER This document is for guidance only. Professional advice should be obtained before acting on any information contained herein. Last up date : December 2010 1 1. INDIVIDUAL INCOME
Netherlands General Netherlands 1. What are recent tax developments in your country which are relevant for M&A deals? Most recent tax developments in the Netherlands are based on the OECD (BEPS) and EU
UK CLIENT MEMORANDUM ENGLISH LAW UPDATES What Are the Tax Reasons Favouring the United Kingdom as a Holding Company Location May 13, 2014 AUTHOR Judith Harger Recent activity in the merger and M&A space
According to a recent International Monetary Fund study, Australia is in the top ten wealthiest countries in the world. With an educated and skilled workforce, it presents great opportunity for expansion.
Worldwide personal tax guide 2013 2014 Canada Local information Tax Authority Website Tax Year Tax Return due date Is joint filing possible Are tax return extensions possible Canada Revenue Agency (CRA)
Laos Tax Profile Produced in conjunction with the KPMG Asia Pacific Tax Centre Updated: June 2015 Contents 1 Corporate Income Tax 1 2 Income Tax Treaties for the Avoidance of Double Taxation 5 3 Indirect
2015/16 FOREWORD A country's tax regime is always a key factor for any business considering moving into new markets. What is the corporate tax rate? Are there any incentives for overseas businesses? Are
Legal Aspects of Doing Business in Russia Dmitry Labin Professor, Moscow Institute of International Relations (MGIMO University) Senior Counsel, Danilov & Konradi LLP ROADSHOW Portugal Global, 22 September
www.pwc.com/goingglobal Real Estate Going Global Singapore Tax and legal aspects of real estate investments around the globe 2012 Real Estate Going Global Singapore 1 Contents Contents Contents... 2 Real
Taxation (International and Other Provisions) Act 2010 CHAPTER 8 Explanatory Notes have been produced to assist in the understanding of this Act and are available separately 43.50 Taxation (International
Cyprus Country Profile EU Tax Centre July 2015 Key tax factors for efficient cross-border business and investment involving Cyprus EU Member State Yes Double Tax Treaties With: Armenia Austria Azerbaijan
EFFECTIVE INTERNATIONAL INTELLECTUAL PROPERTY STRATEGIES TO MITIGATE U.S. TAXES DENNIS S. FERNANDEZ INNA S. SHESTUL Fernandez & Associates, L.L.P. Fernandez & Associates, L.L.P. 1047 El Camino Real, Ste
International Tax Australia Tax Alert Contacts Peter Madden email@example.com Claudio Cimetta firstname.lastname@example.org Vik Khanna email@example.com Alyson Rodi firstname.lastname@example.org David Watkins
May 2009 Ernst & Young Shinnihon Tax JAPAN Newsletter UK Tax Update 2009 Contents 1. Dividend exemption 2. Worldwide Debt Cap ( WWDC ) 3. Tax and Risk Management The UK Government has recently published
Thailand Tax Profile Produced in conjunction with the KPMG Asia Pacific Tax Centre Updated: November 2013 Contents 1 Corporate Income Tax 1 2 International Treaties for the Avoidance of Double Taxation
Your consent to our cookies if you continue to use this website.