Investing in Latin America through Spain: Planning Opportunities

Save this PDF as:
 WORD  PNG  TXT  JPG

Size: px
Start display at page:

Download "Investing in Latin America through Spain: Planning Opportunities"

Transcription

1 Investing in Latin America through Spain: Planning Opportunities 11th Annual Latin American Tax Conference Miami, Florida March 2010 Luis Carbajo, Isabel Otaola, Joaquin Kersman, Clarissa Machado, Miguel Zamora, Jaime Vargas, Luis Jimenez, Ronald Evans

2 Agenda Host Country for Holding Companies Taxation at Source Comparison: Domestic Law and Tax Treaties Spanish holding companies (ETVE) and practical experience. Taxation of holding company shareholders. Special emphasis on ETVEs 2

3 Host Country for Holding Companies 3

4 Holding Companies Requirements Tax Requirements Exemption or reduced tax on the distribution of dividends or sale of shares in the investment country. Exemption or reduced tax on dividends and capital gains in the holding company. Tax Treaties with the target and investment countries investment. Facilitating Authorities providing binding rulings: legal security. Exemption or reduced tax in the holding company country on the distribution of dividends or sale of shares in the holding company by shareholders. 4

5 Holding Companies Requirements Non-tax requirements Communications, accessibility, existence of a network of professional services and possibility to receive services that provide the holding company with financial substance. Good network of Bilateral Investment Protection Treaties (BIPT): Agreements for mutual promotion and protection of investments. Protection against nationalization or expropriation. Guarantees in the event of armed conflict, revolution or similar. Fair treatment vis-à-vis investors from other countries. Free transferability of payments. International Arbitration. 5

6 Why Spain? Wide Treaties Network COUNTRY ARGENTINA BOLIVIA BRAZIL COLOMBIA COSTA RICA CUBA CHILE ECUADOR EL SALVADOR GUATEMALA BIPT NO CDI NEGOC. NO Spain has signed Bilateral Investment Protection Treaties (Acuerdo de Promoción y Protección de Inversiones) with all Latin-American countries except Brazil, Haiti and Paraguay. HAITI HONDURAS MÉXICO NICARAGUA PANAMA PARAGUAY PERU NO NO NO NO NO PF NO NEGOC. Spain has signed Tax Treaties with most of the Latin-American countries. DOMINICAN REP. NO URUGUAY NEGOC. VENEZUELA 6

7 Taxation at Source Comparison: Domestic Law and Tax Treaties 7

8 Argentine Tax treatment WHT on dividends: General treatment: WTH at 35% on the portion exceeding the income obtained by the Argentine Company in the fiscal year. Held by ETVE: maximum of 10% if ETVE holds more than 25% of the shares. Otherwise, 15% WHT on capital gains: General treatment: local taxpayers WHT at 9%/35%. May not apply for individuals. Foreign beneficiaries: exemption on shareholding (corporations) Held by ETVE, maximum of 10% if ETVE holds more than 25% of the shares. Otherwise, 15% 8

9 Argentine Wealth tax: Applicable at 0.5% Held by ETVE, no tax impact on operating subsidiary's equity. Application of DTT. Concerns Utilization of tax credit for any WHT Formal requirements for the DTT to apply 9

10 Brazil Dividends: 0% withholding income tax ( WHT ) regardless of the domicile of the beneficiary Interest on Equity: 15% WHT (or 25% if beneficiary domiciled in low tax jurisdiction). Deductible expense in Brazil. Potential issue: treatment abroad Dividends? Interest? 10

11 Brazil Capital Gain: 15% WHT (or 25% if seller is domiciled in a low tax jurisdiction) Applicable also in case only the asset is located in Brazil (nonresident buyer and non-resident seller) Brazilian attorney-in-fact of buyer is responsible for the payment Tax treaties do not provide lower tax burden (except Japan) 0% WHT may apply in case sale of publicly traded shares in the Brazilian stock exchange (plus other requirements) 0.38% Financial tax (IOF Exchange) upon the remittance of funds abroad. Some exceptions may apply. 11

12 Chile Non-residents in Chile are subject to income taxation in Chile on their Chilean source income. Exception: alien individuals are subject to taxes in Chile exclusively on their Chilean source income during the first 3 years of stay in the country. Income is considered sourced in Chile when the activities are carried on within Chilean territory or when the assets are located in the country. Special rules: Interest accrued of a loan when the debtor is a Chilean resident Shares of a corporation formed in Chile and of interest in LLC/limitada also formed in the country. Capital again arising from the alienation of shares of a foreign company that controls a Chilean Target, provided that the acquiring party is resident in Chile. 12

13 3. Chile (cont.) Dividends taxation: Chile has an imputation system according to which dividends paid to non-residents shareholders are subject to a 35% WHT against which the 17% Corporate Tax paid on the item of income distributed is creditable (total tax burden of 35%). Considering this special feature of the Chilean income taxation, Chile has negotiated in all its tax treaties that the rate reduction of the dividends taxation generally contained in tax treaties is not applicable to Chile while Chile maintains the imputation income tax system explained above. This is the case of all tax treaties currently in force in Chile, including the one with Spain. 13

14 Chile Capital Gains Taxation: There is no capital gains tax as such in Chile. Capital gains arising from the alienation of shares of a corporation formed in Chile is either subject to a 17% tax or deemed ordinary income subject in the hands of a non-resident shareholder to a 17% Corporate Tax and to a 35% WHT less the credit for the Corporate Tax paid. The application of the tax depends on the seniority of the holding (1 year or more), if the alienation takes place among related parties or not and if the seller is to be considered a trader or an habitual seller of shares. In exceptional cases the capital gain is exempt from taxation e.g. (i) when held since 1984, (ii) in the case of publicly traded shares with a certain market presence and (iii) in the hands of an institutional investor. The general rule of the tax treaties negotiated by Chile is that Chile retains taxation right on capital gains arising from the alienation of shares of a corporation formed in Chile. Only specific treaties reduces the Chilean taxation and the treaty with Spain is one of them. 14

15 Mexico Capital Gains The transfer of title to shares issued by a Mexican company is subject to Mexican federal income tax, at a rate of 25% on a gross basis, or of 30% on a net basis, as the seller may elect. This second option is only available when the non-resident transferor is not subject to a preferential tax regime (i.e., it is not subject to less than 75% of the income tax payable under Mexican tax law) and the seller designates a legal representative in Mexico (this can be an individual or a corporation, in both cases resident in Mexico for tax purposes). The transferor is also subject to Mexican federal income tax on the sale of shares issued by non-mexican companies when the assets thereof are mainly represented by real estate property located in Mexico. 15

16 Mexico Dividends distributions Dividends distributed by Mexican companies are not subject to income tax withholding. Mexican companies that distribute dividends are subject to income tax if they do not have balance in their Net After Tax Profit Account (CUFIN). 16

17 Venezuela Dividend distributed out of untaxed profits are subject to 34%. In most cases, Corporate Income Tax may not be totally or partially due to inflation adjustments. Capital gains derived from disposal of shares of Venezuelan companies is taxed in Venezuela regardless of the residence of the holder or place of payment. Except in case of a Tax Treaty 17

18 Taxation at Source - comparison table (1) México Venezuela Colombia Domestic legislation Best Tax Treaty Spain The Netherlands Luxembourg Austria Capital Capital Capital Capital Capital Divid. gains Divid. gains Divid. gains Divid. gains Divid. 0% (if CUFIN) 0% (if profits have been taxed in Venezuela) 0% (if profits have been taxed Colombia) 25%(gross)/ 30%(net) Up to 34% 33% Argentina 0%/35% 0%/35% Chile 35% (17% is deductible) 17% Brazil 0% 15% Domestic legislation Domestic legislation Domestic legislation 0%: among others, Italy or Switzerland 5% (=>25%)/15% 0%: among others, Spain, 0% (=> 25%) / Germany, the 10% Netherlands or Switzerland Spain 0% (=> 20%) / 5% 25% (net) if =>25%+12 months). 0% 0% 5% (=>10%)/15% 10% (net) 8% (=>10%)/15% 0% (=> 25%) / 10% 10% 10% 10% 10% 10% (=>25%)/15% N/A (=>25%)/15% (=>25%)/15% (=>25%)/15% (=>25%)/15% 5%, among others, Spain, UK or Sweden Domestic legislation 16%: among others, France, Ireland, Portugal or UK 0% : Japan 5% (=>20%)/10% 10% (=>25%)/ 15% 17% (=>20%+12 months) / 16% N/A 0% 15% 15% 15% N/A gains Divid. Capital gains Divid. Taxable if =>25% or 5% (=>10%) exempted / 10% 20% (net) Non taxable in Lux. 5% (=>15%) / 15% N/A N/A N/A N/A 15% (=>10%) / 25% N/A Up to 34% if participation is equal or higher than 10% of the assets of the transferred company N/A N/A 15% 15% 15% UK 0% (=> 10%)/10 % Capital gains Taxable if =>25%+12 months). Up to 34 % > 50% value = inmovable property 10% 10% (=>25%)/15 (=>25%)/15% 5% (=> 20%)/15 % N/A N/A % 17% (=> i) 20%+12 months or ii) + 50% value = inmovable property) / 16% (1) Does not consider taxation of real estate companies or business reorganisations. 18

19 Comparison Table: Conclusions Spain is a good country for investment in companies resident in Venezuela and Colombia and even Chile (given the existence of Tax Treaty). Argentina: Wealth/Asset Tax is avoided. Mexico: although capital gains from shares are taxed in Mexico pursuant to both domestic law and Tax Treaty, the Tax Treaty contains a deferral clause in the event of business reorganizations. The Netherlands can also be an alternative for Mexico, although there are no Tax Treaties in place with Colombia or Chile. Brazil: There is no substantial difference between investing through Spain or through The Netherlands. 19

20 Spanish holding companies (ETVE) and practical experience. 20

21 Spanish Holding Companies: ETVE Exemption of dividends and capital gains from the transfer of shares in operating companies. Very good Tax Treaty network: Mexico, Brazil, Argentina, Colombia, Chile, Venezuela, Bolivia, Cuba, Ecuador, El Salvador Uruguay and Costa Rica: signed and pending publication. Peru: negotiated. Distribution of dividends by an ETVE to a non-resident shareholder in Spain and capital gains on the sale of ETVE shares not subject to tax. Very good network of BIPT: Argentina, Bolivia, Costa Rica, Cuba, Chile, Ecuador, El Salvador, Guatemala, Honduras, Mexico, Nicaragua, Panamá, Paraguay, Peru, Dominican Republic, Uruguay and Venezuela. Colombia: signed and pending publication. 21

22 Spanish Holding Companies: ETVEs Possibility of submitting binding rulings to the Tax Authorities. Same language (except for Brazil), very good communication and accessibility. Corporate purpose must include the holding and management of the participation, but needs not be exclusive. 5% direct or indirect participation or 6M (acquisition cost). Minimum holding period of 12 months (before or after). Subsidiary subject to similar Corporate Income Tax (CIT). Performance of business activity abroad by subsidiary: 85% test and no Controlled Foreign Corporation (CFC) rules. 22

23 Practical Experience with ETVEs: critical issues Material and human resources to manage the participation in the subsidiary Lack of well-defined Spanish law. Rulings. Sufficient organizational means to exercise rights and fulfill obligations as a shareholder. At least 1 Member of the Board of Directors (or one employee) responsible for such obligations. Document all communications relating to the exercising of such rights and fulfillment of obligations. 23

24 Practical Experience with ETVEs: critical issues Subject to similar CIT: Fulfilled if the subsidiary is resident in a country with a Tax Treaty containing an information exchange clause. All Tax Treaties signed by Spain. Tax havens excluded. Broad definition of similar CIT: taxing income, revenue or any other earnings indicator. Special consideration for territorial tax regimes (Costa Rica or Uruguay): considered fulfilled only with regard to income subject to tax in such jurisdictions. 24

25 Practical Experience with ETVEs: critical issues 85% of income from business activity abroad: Non-applicable to CFC income. Safe harbour: 15% of income may proceed from companies located in tax havens or that do not fulfil requirements. Admissibility of intermediary holding companies between the ETVE and the operating subsidiary. Individual calculation of test on direct subsidiary. 25

26 Practical Experience with ETVEs: Conclusions Good practical experience, despite complexity of test on 85% of business activity abroad. Important to review fulfillment of requirements before the end of each year. For dividends, only the year in which income is earned is taken into account. For capital gains, requirements must be fulfilled in all years during which the participation is held. 26

27 Holding Company Comparison Table: Spain, Austria, Luxembourg and The Netherlands. Dividends Spain Austria Luxembourg The Netherlands -Exemption regime -Minimum participation - Time requirement - Subsidiary taxation requirement Capital gains 100% 5% or 6M 1 year No if Tax Treaty exists 100% 10% 1 year No 100% 10% or 1.2M 1 year Yes outside EU (11%) 100% 5% No No (except passive assets) -Exemption regime 100% 100% 100% 100% -Minimum participation - Time requirement - Subsidiary taxation requirement CFC 5% or 6M 1 year No if tax Treaty exists Yes 10% 1 year No No 10% or 6M 1 year Yes outside EU (11%) No 5% No No (except passive assets) No Capital Duty 1%, except for business re-structuring 1%, except business re-structuring No No Holding tradition Medium / High Medium High High 27

28 Taxation of holding company shareholders. Special emphasis on ETVEs 28

29 Taxation of ETVE Shareholders in Spain Non-resident shareholders, either individuals or companies, are not subject to taxation in Spain: On dividends distributed by ETVEs arising from tax-exempt income. If not arising from tax-exempt income, applicable tax rate of 19% except for EU (if the requirements set forth in the Parent- Subsidiary Directive are fulfilled) or Tax Treaty. On capital gains from the sale of the ETVE participation corresponding to reserves derived from tax-exempt income and on the goodwill attributable to subsidiaries qualifying for application of the CIT exemption. If not arising from tax-exempt income or the subsidiary does not qualify, the applicable tax rate will be 19%, except for Tax Treaty or EU (in certain cases). 29

30 Taxation of ETVE Shareholders in Spain Subject to tax (at a rate of 19%) if the non-resident shareholder is resident in a country classified as a tax haven: The Dutch Antilles and Aruba are no longer considered as tax havens as a result of the signing of an information exchange agreement. Andorra has already signed such agreement, which nevertheless is yet to be published. 30

31 Taxation of ETVE Shareholders ETVE dividends and capital gains: Spanish Non-resident Income Tax = 0% Non-resident shareholder (ind. or company) Not in a tax haven Subsidiary dividends and capital gains: CIT = 0% Non-exclusive corporate purpose ETVE Material or human resources At least 5% participation and 12 month holding period Dividends and capital gains on the sale of shares in the operating company: Tax Treaty or according to domestic law Profits on activity according to jurisdiction CIT Non-resident operating company Tax Treaty or similar CIT Business activity abroad Not in a tax haven (up to 15% income) 31

32 Comparison of tax rates applicable to holding company shareholders according to domestic law Spain Austria Luxembourg The Netherlands (ETVE) Dividends 0% 25% 15% 15% Capital gains 0% Individual shareholder: 25% 0% (generally) 0% (generally) Company shareholder: 0% 32

33 Taxation of ETVE Argentine Shareholders No CFC Rules applicable / Deferral Obtainable Income Tax Dividends: 35% - Only applicable upon distribution Capital gains: 9% - 35%. May not apply for individuals Double taxation avoidance: tax credit Argentine Wealth Taxes: Individuals may be subject to Personal Assets tax at a progressive rate ranging from 0.50% to 1.25% to the extent that the value of their assets exceeds AR$ 305,000 Legal entities may be subject to a 1% MPIT creditable/offsetable against IT Other jurisdictions: Dividends Germany: tax credit UK: tax credit 33

34 Taxation of ETVE Brazilian Shareholders Income / Dividends General Rule: taxation of foreign subsidiary profits by year-end, based on Brazilian CFC Rules; Arguments to support the deferral or non-taxation, based on Article 7 (Business Profit) and/or Article 23, 4 of the Brazil-Spain Treaty; A Brazil ETVE B C Article 23, 4: Where a resident of Brazil derives dividends which, in accordance with the provisions of this Convention may be taxed in Spain, Brazil shall exempt such dividends from tax. 34

35 Taxation of ETVE Brazilian Shareholders Income / Dividends (cont.) Existing tax assessments on this matter; Article 23, 4 does not apply in case of ETVE; Best alternative from a Brazilian standpoint: non-etve company. Capital Gain Sale of ETVE (or other non-resident entity) by a Brazilian entity: 34% corporate income tax on the gain. ADI SRF nº 6/2002: Are submitted to the incidence of taxes on income the profit and dividends received by residents or parties that are domiciled in Brazil, deriving from the participation in Entidad de Tenencia de Valores Extranjeros /ETVE, regulated by the Spanish Law of the Societies Tax, not applying to the arranged in 4 of Article 23 of the Brazil-Spain Treaty. 35

36 Taxation of ETVE Chilean Shareholders Assuming that the ETVE distributes a dividend to a shareholder resident of Chile, such dividend will be taxable in Chile. According to the tax treaty between Chile and Spain Chile must grant a credit on taxes paid in Spain according to the credit rules existing in Chile. According to foreign tax credit rules existing in Chile a credit for taxes paid abroad is recognized only with regards to the specific country from the relevant item of income is received. Therefore, the Chilean shareholder of the ETVE may not use as a credit against Chilean taxes, the Corporate Tax and/or WHT paid on the source jurisdiction from where the 36

37 Taxation of ETVE Chilean Shareholders Assuming that a Chilean resident shareholder of an ETVE alienates its shares, the capital gain is taxable according to the tax treaty between Chile and Spain (Chile is the residency country) and further because in Chile local residents are subject to taxation on their items of income regardless of its source. Considering that no taxes would be paid in Spain on the capital gain derived, no credit would be available in Chile. 37

38 Taxation of ETVE Mexican Shareholders Income Tax: Dividends received from non-mexican companies are taxable as any other revenue (30% on the annual taxable income), but it is possible to claim foreign tax credit if the Mexican company owns at least 10% of the equity for the prior 6 months to the date of the dividend distribution. Capital gains are taxable as any other revenue (30% on the annual taxable income). Carryforward losses can be used against dividends or capital gains. Business flat rate tax: Neither dividends nor capital gains are subject to this tax 38

39 Taxation of ETVE Venezuelan Shareholders Distribution of dividends by ETVE to a Venezuelan shareholder will be taxed at 34% in Venezuela. Deferral may be obtained by using an NV in Curacao owned by a NZ trust. CFC rules would not apply. Income would only be taxed if actually distributed to Venezuelan resident. 39

40 Alternatives ETVE Structure Direct Investor Trust Direct Investor Direct Investor Blocker (N. Antilles UE) Trustee ETVE LATAM 40

41 Thank you Baker & McKenzie International is a Swiss Verein with member law firms around the world. In accordance with the common terminology used in professional service organizations, reference to a partner means a person who is a partner, or equivalent, in such a law firm. Similarly, reference to an office means an office of any such law firm.

Managing payments from and to Latin America: Reducing your company's tax burden

Managing payments from and to Latin America: Reducing your company's tax burden Managing payments from and to Latin America: Reducing your company's tax burden Latin America 2010: Proactive Strategies for Doing Business in Today's Changing Landscape Miami, Florida March 17, 2010 Why

More information

Techniques for Repatriation of Funds

Techniques for Repatriation of Funds Techniques for Repatriation of Funds Baker & McKenzie 11th Annual Latin American Tax Conference March 10 and 11, 2010 The Biltmore Hotel, Coral Gables Florida Martin Barreiro- (Buenos Aires) Jaime Vargas

More information

Colombia Taxation FUNDS AND FUND MANAGEMENT Taxation of funds. Investment funds. Foreign capital investment funds

Colombia Taxation FUNDS AND FUND MANAGEMENT Taxation of funds. Investment funds. Foreign capital investment funds Colombia Taxation FUNDS AND FUND MANAGEMENT 2010 3.1 Taxation of funds Investment funds Investment funds and securities funds are not taxable in Colombia. These funds are deemed as non taxable as regards

More information

Treatment of capital gains in mining projects in Ecuador

Treatment of capital gains in mining projects in Ecuador Treatment of capital gains in mining projects in Ecuador September 2015 CAPITAL GAINS TA IN LATIN AMERICA Is the indirect disposal of shares taxed? Country Taxes Does not tax Brazil Argentina Chile Colombia

More information

Greece Country Profile

Greece Country Profile 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

More information

Why Spain? Why Austria?

Why Spain? Why Austria? 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

More information

PRIVATE CLIENTS RESIDENT IN CHILE

PRIVATE CLIENTS RESIDENT IN CHILE PRIVATE CLIENTS RESIDENT IN CHILE BASIC ISSUES JUNE 2012 ARTURO GARNHAM Index Basic tax rules. Types of tax deferral IT Systems and Privacy Credit Card Cases & LGT Bankers: Birkenfeld, Liechti, Schaffner

More information

Taxation of Cross-Border Mergers and Acquisitions

Taxation of Cross-Border Mergers and Acquisitions 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

More information

Recent developments regarding Mexico s tax treaty network and relevant court precedents

Recent developments regarding Mexico s tax treaty network and relevant court precedents Recent developments regarding Mexico s tax treaty network and relevant court precedents Mexico has a relatively short background on the negotiation and application of treaties for the avoidance of double

More information

Dealing with tax complexities in Brazil

Dealing with tax complexities in Brazil Dealing with tax complexities in Brazil By: Dudley Juana Anderson Dutra AGENDA Tax complexities in Brazil 1. Overview of main taxes in Brazil IRPJ and CSLL Gross Revenue Taxes: PIS and COFINS Indirect

More information

Income in the Netherlands is categorised into boxes. The above table relates to Box 1 income.

Income in the Netherlands is categorised into boxes. The above table relates to Box 1 income. 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

More information

U.S. Taxation of Foreign Investors

U.S. Taxation of Foreign Investors PART OF THE LEHMAN TAX LAW KNOWLEDGE BASE SERIES United States Taxation Of Investors U.S. Taxation of Foreign Investors Non Resident Alien Individuals & Foreign Corporations By Richard S. Lehman Esq. TAX

More information

Mexico Mergers and acquisitions involving Mexican assets

Mexico Mergers and acquisitions involving Mexican assets p84-88 IM&A - Chevez Rulz 21/03/2013 08:44 Page 84 Mexico Mergers and acquisitions involving Mexican assets by Ricardo Rendon and Layda Carcamo, Chevez, Ruiz, Zamarripa y Cia, S.C. Whenever a corporate

More information

CYPRUS TAX CONSIDERATIONS

CYPRUS TAX CONSIDERATIONS 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

More information

Taxation in South America

Taxation in South America Taxation in South America Agenda Overview of Taxation in the Region Particularities for Construction Market Review of Major Economies 1- Overview Benefits for Canadians Developed treaty network with Canada

More information

INTERNATIONAL FACTORING

INTERNATIONAL FACTORING INTERNATIONAL FACTORING November 3, 2011 1 L. Gabriel Segura President and founding officer of CVCredit Inc, a Miami-based company which focuses in USA-domestic and international factoring services. Nine

More information

Tax Impacts to Structure Investments in Brazil Debt or Equity. Andrea Bazzo Lauletta November 2012

Tax Impacts to Structure Investments in Brazil Debt or Equity. Andrea Bazzo Lauletta November 2012 Tax Impacts to Structure Investments in Brazil Debt or Equity Andrea Bazzo Lauletta November 2012 Introduction Brazilian Scenario for Non-Resident Investments Brazil has a specific set of rules for non-resident

More information

TAXATION OF INTEREST, DIVIDENDS AND CAPITAL GAINS IN CYPRUS

TAXATION OF INTEREST, DIVIDENDS AND CAPITAL GAINS IN CYPRUS 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

More information

Spain's 2015 tax reform approved: What foreign investors and M&A players should know

Spain's 2015 tax reform approved: What foreign investors and M&A players should know Spain's 2015 tax reform approved: DECEMBER What foreign investors and M&A players should know Spain's 2015 Tax Reform approved: What foreign investors and M&A players should know 1 Contents 1. Tax deduction

More information

Module IV: Corporate Tax Planning Update:

Module IV: Corporate Tax Planning Update: Module IV: Corporate Tax Planning Update: Colombia and Venezuela 11th Annual Latin American Tax Conference Miami, Florida 10-11 March 2010 Jaime Vargas, Sergio Corredor and Jorge Jraige Agenda COLOMBIA

More information

Future Focus 2011 Iberoamerica Tax Summit. 4-6 October, 2011 Rio de Janeiro, Brazil

Future Focus 2011 Iberoamerica Tax Summit. 4-6 October, 2011 Rio de Janeiro, Brazil Future Focus 2011 Iberoamerica Tax Summit 4-6 October, 2011 Rio de Janeiro, Brazil Aligning Business with the New Reality Transfer Pricing Opportunities Focus Session 5 October, 2011 Rio de Janeiro, Brazil

More information

Annual International Bar Association Conference 2014. Tokyo, Japan. Recent Developments in International Taxation. Portugal. Guilherme Figueiredo

Annual International Bar Association Conference 2014. Tokyo, Japan. Recent Developments in International Taxation. Portugal. Guilherme Figueiredo Annual International Bar Association Conference 2014 Tokyo, Japan Recent Developments in International Taxation Portugal Guilherme Figueiredo Eurofin Capital S.A. gfigueiredo@eurofincapital.com 1. RECENT

More information

SYLLABUS BASICS OF INTERNATIONAL TAXATION. ! States levy taxes by virtue of their sovereignty

SYLLABUS BASICS OF INTERNATIONAL TAXATION. ! States levy taxes by virtue of their sovereignty SYLLABUS BASICS OF INTERNATIONAL TAXATION! States levy taxes by virtue of their sovereignty! Tax sovereignty, however, is not unlimited. There must either be a personal or an objective connection between

More information

Brazil: Inbound Cross-Border Tax Issues

Brazil: Inbound Cross-Border Tax Issues Brazil: Inbound Cross-Border Tax Issues ABA Section of Taxation 2009 May Meeting Ana Cláudia Akie Utumi autumi@tozzinifreire.com.br Ana Claudia Akie Utumi autumi@tozzinifreire.com.br Professional experience:

More information

Real estate acquisition structures in Europe: the main tax issues

Real estate acquisition structures in Europe: the main tax issues Real estate acquisition structures in Europe: the main tax issues The increasing budget requirements of European countries and their implications for taxpayers CMS Annual Tax Conference - Thursday 9 February

More information

Spain Tax Alert. Corporate tax reform enacted. Tax rate. Tax-deductible expenses. International Tax. 2 December 2014

Spain Tax Alert. Corporate tax reform enacted. Tax rate. Tax-deductible expenses. International Tax. 2 December 2014 International Tax Spain Tax Alert 2 December 2014 Corporate tax reform enacted Contacts Brian Leonard bleonard@deloitte.es Francisco Martin Barrios fmartinbarrios@deloitte.es Elena Blanque elblanque@deloitte.es

More information

Taxation of Cross-Border Mergers and Acquisitions

Taxation of Cross-Border Mergers and Acquisitions KPMG INTERNATIONAL Taxation of Cross-Border Mergers and Acquisitions Mexico kpmg.com 2 Mexico: Taxation of Cross-Border Mergers and Acquisitions Mexico Introduction Foreign investment in Mexico by multinationals

More information

INTRODUCTION TO THE TAXATION SYSTEM IN ISRAEL

INTRODUCTION TO THE TAXATION SYSTEM IN ISRAEL INTRODUCTION TO THE TAXATION SYSTEM IN ISRAEL 1. INTRODUCTION The Israeli tax system is based on UK tax principles with substantial modification. On January 1, 2003, Israel introduced a substantial tax

More information

Incorporating International Tax Laws in Multinational Capital Budgeting

Incorporating International Tax Laws in Multinational Capital Budgeting APPENDIX 14 Incorporating International Tax Laws in Multinational Capital Budgeting Tax laws can vary among countries in many ways, but any type of tax causes an MNC s after-tax cash flows to differ from

More information

How Much Do U.S. Multinational Corporations Pay in Foreign Income Taxes?

How Much Do U.S. Multinational Corporations Pay in Foreign Income Taxes? FISCAL FACT May. 2014 No. 432 How Much Do U.S. Multinational Corporations Pay in Foreign Income Taxes? By Kyle Pomerleau Economist Key Findings The United States worldwide system of corporate taxation

More information

Netherlands Country Profile

Netherlands Country Profile Netherlands Country Profile EU Tax Centre March 2012 Key factors for efficient cross-border tax planning involving Netherlands EU Member State Yes Double Tax Treaties With: Albania Czech Rep. Jordan Nigeria

More information

THE HISTORY OF DOUBLE TAX CONVENTIONS (The DTC-Policy over the years) Mexico Report. by Santiago Solórzano and Alejandro Calderón

THE HISTORY OF DOUBLE TAX CONVENTIONS (The DTC-Policy over the years) Mexico Report. by Santiago Solórzano and Alejandro Calderón THE HISTORY OF DOUBLE TAX CONVENTIONS (The DTC-Policy over the years) Mexico Report by Santiago Solórzano and Alejandro Calderón 2 Background Mexico is the only Latin-American country member of the OECD.

More information

Brazilian interest payments on net equity (Juros sobre o capital próprio): an international perspective

Brazilian interest payments on net equity (Juros sobre o capital próprio): an international perspective Brazilian interest payments on net equity (Juros sobre o capital próprio): an international perspective 1. Interest on Equity and Dividends: the Brazilian perspective Brazilian companies have two main

More information

TAX ISSUES RAISED BY LNG PROJECTS

TAX ISSUES RAISED BY LNG PROJECTS TAX ISSUES RAISED BY LNG PROJECTS Jon Lobb Baker Botts L.L.P. ABSTRACT This paper discusses tax issues that may be encountered by a company investing in an LNG project. 1. Income Taxes A seller's income

More information

Holding companies in Ireland

Holding companies in Ireland 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

More information

BLUM Attorneys at Law

BLUM Attorneys at Law BLUM Attorneys at Law CORPORATE TAXATION SYSTEM IN SWITZERLAND Outline of Swiss Corporate Tax System Levels of Taxation in Switzerland Resident companies are subject to: federal corporate income tax, and

More information

Europe. NEW OPPORTUNITIES FOR DIVIDEND WITHHOLDING TAX REFUNDS EU / EEA Tax Exempt Entities Handbook

Europe. NEW OPPORTUNITIES FOR DIVIDEND WITHHOLDING TAX REFUNDS EU / EEA Tax Exempt Entities Handbook Europe NEW OPPORTUNITIES FOR DIVIDEND WITHHOLDING TAX REFUNDS EU / EEA Tax Exempt Entities Handbook 3rd Edition April 2012 I n t r o d u c t i o n We are pleased to present the third edition of this handbook,

More information

The use of Cyprus structures in international tax planning

The use of Cyprus structures in international tax planning The use of Cyprus structures in international tax planning Tax and other advantages Tax planning ideas - structures 1 Terms of reference Purpose - basis of preparation - assumptions: This presentation

More information

European Tax Newsalert A Washington National Tax Services (WNTS) Publication Portugal December 20, 2011

European Tax Newsalert A Washington National Tax Services (WNTS) Publication Portugal December 20, 2011 European Tax Newsalert A Washington National Tax Services (WNTS) Publication Portugal December 20, 2011 Portugal 2012 Budget Act The Portuguese Parliament approved the 2012 Budget Act on November 30, 2011.

More information

ENCHANCING PORTUGUESE CORPORATE TAX REGIME

ENCHANCING PORTUGUESE CORPORATE TAX REGIME 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,

More information

TAX PRACTICE GROUP Multi-Jurisdictional Survey TAX DESK BOOK

TAX PRACTICE GROUP Multi-Jurisdictional Survey TAX DESK BOOK 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

More information

The Advantages of the UK as a Location for a Holding Company. David Gibbs May 2015

The Advantages of the UK as a Location for a Holding Company. David Gibbs May 2015 The Advantages of the UK as a Location for a Holding Company David Gibbs May 2015 The UK is an attractive location to site an international holding company since not only does it offer a relatively stable

More information

Common Working Theory into Practice

Common Working Theory into Practice Common Working Theory into Practice European Conference Warsaw, July 2010 Peter Karl Plattner Emigration and Immigration - Italy Emigration from Italy abandonment of residence prerequisite: abandonment

More information

Ireland Country Profile

Ireland Country Profile Ireland Country Profile EU Tax Centre July 2015 Key tax factors for efficient cross-border business and investment involving Ireland EU Member State Yes Double Tax Treaties With: Albania Armenia Australia

More information

Energy Briefing: Global Crude Oil Demand & Supply

Energy Briefing: Global Crude Oil Demand & Supply Energy Briefing: Global Crude Oil Demand & Supply November 6, 215 Dr. Edward Yardeni 516-972-7683 eyardeni@ Debbie Johnson 48-664-1333 djohnson@ Please visit our sites at www. blog. thinking outside the

More information

Software Tax Characterization Helpdesk Quarterly June 2008

Software Tax Characterization Helpdesk Quarterly June 2008 & McKenzie Software Tax Characterization Helpdesk Quarterly June 2008 Characterizing foreign software revenues is a complex challenge for large and small software firms alike. Variations in the rules around

More information

Value through Wealth Planning - Key trends in taxation of private investors. Prof. Pierre-Marie Glauser

Value through Wealth Planning - Key trends in taxation of private investors. Prof. Pierre-Marie Glauser Value through Wealth Planning - Key trends in Prof. Pierre-Marie Glauser Introduction (1) Wealth Management & Taxes Funds are Not declared Declared No taxes due Tax planning not necessary Relevant tax

More information

THE ISRAELI TAX SYSTEM. Iris Stark, CPA

THE ISRAELI TAX SYSTEM. Iris Stark, CPA THE ISRAELI TAX SYSTEM Iris Stark, CPA October 2012 THE ISRAELI TAX SYSTEM Taxation in Israel is based on an individual method. Accordingly, as of 2003, all Israeli residents are liable for payment of

More information

Malta Companies in International Tax Structuring February 2015

Malta Companies in International Tax Structuring February 2015 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.

More information

Evolution of EU exports and imports of goods with CELAC, 2004-2014 (in billion)

Evolution of EU exports and imports of goods with CELAC, 2004-2014 (in billion) 100/2015-9 June 2015 EU Community of Latin American and Caribbean States (CELAC) summit CELAC represents the fifth most important trading partner of the EU More than 200 bn total trade The 28 Member States

More information

Tourism Statistical Yearly Report 2012

Tourism Statistical Yearly Report 2012 Tourism Statistical Yearly Report 2012 The Costa Rica Tourism Board is pleased to present the Tourism Statistical Yearly Report 2012. The information has been collected and organized by officers of Subproceso

More information

Spanish Tax Facts. The Expatriate Financial Guide to Spain

Spanish Tax Facts. The Expatriate Financial Guide to Spain The Expatriate Financial Guide to Spain Spanish Tax Facts Introduction Tax Year Assessment Basis Taxation in Spain occurs at a national level and at a regional ( Autonomous Community ) or municipal level.

More information

Foreign Person Investing in U.S. Real Estate

Foreign Person Investing in U.S. Real Estate Foreign Person Investing in U.S. Real Estate Ian Shane Golenbock Eiseman Assor Bell & Peskoe LLP TTN New York Conference 2013 Foreign Purchases of U.S. Homes Foreign Home Buyers want to: Minimize tax on

More information

450 Lexington Ave 1350 I Street, NW Suite 3320 Suite 1100 New York, NY 10017 Washington, DC 20005

450 Lexington Ave 1350 I Street, NW Suite 3320 Suite 1100 New York, NY 10017 Washington, DC 20005 Eric van Aalst Mark Riedy Citco Corporate Services Inc. Andrews Kurth LLP 450 Lexington Ave 1350 I Street, NW Suite 3320 Suite 1100 New York, NY 10017 Washington, DC 20005 Structuring International Operations

More information

Tax Reform in Brazil and the U.S.

Tax Reform in Brazil and the U.S. Tax Reform in Brazil and the U.S. Devon M. Bodoh Principal in Charge Latin America Markets, Tax KPMG LLP Carlos Eduardo Toro Director KPMG Brazil Agenda Overview of Global Tax Reform Overview Organization

More information

German Tax Facts. The Expatriate Financial Guide to Germany

German Tax Facts. The Expatriate Financial Guide to Germany 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

More information

Withholding Tax Rates Used in Net-of-Tax Indexes v2.3

Withholding Tax Rates Used in Net-of-Tax Indexes v2.3 Withholding Tax Rates Used in Net-of-Tax Indexes v2.3 ftserussell.com February 2016 Contents 1.0 Introduction... 3 2.0 FTSE Global Equity Index Series and Russell Global Indexes... 4 2.1 Maximum Withholding

More information

FedEx International Priority. FedEx International Economy 3

FedEx International Priority. FedEx International Economy 3 SERVICES AND RATES FedEx International Solutions for your business Whether you are shipping documents to meet a deadline, saving money on a regular shipment or moving freight, FedEx offers a suite of transportation

More information

COLOMBIA ISRAEL MEXICO PORTUGAL

COLOMBIA ISRAEL MEXICO PORTUGAL TAXATION OF REAL PROPERTY INDEX ARGENTINA AUSTRIA CHILE GERMANY (DE) COLOMBIA ISRAEL MEXICO PORTUGAL Updated information NOVEMBER 2012 UNITED KINGDOM URUGUAY SPAIN CYPRUS The content of this newsletter

More information

Setting up your Business in Argentina Issues to consider

Setting up your Business in Argentina Issues to consider 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.

More information

WLP LAW. II. The Dutch corporate tax system. INVESTING IN INDIA OR THE UNITED STATES OF AMERICA THROUGH THE NETHERLANDS Tax Alert April 2013

WLP LAW. II. The Dutch corporate tax system. INVESTING IN INDIA OR THE UNITED STATES OF AMERICA THROUGH THE NETHERLANDS Tax Alert April 2013 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

More information

THE ADVANTAGES OF A UK INTERNATIONAL HOLDING COMPANY

THE ADVANTAGES OF A UK INTERNATIONAL HOLDING COMPANY THE ADVANTAGES OF A UK INTERNATIONAL HOLDING COMPANY Ideal Characteristics for the Location of an International Holding Company Laurence Binge +44 (0)1372 471117 laurence.binge@woolford.co.uk www.woolford.co.uk

More information

Module II: Corporate Tax Planning Update: Mexico

Module II: Corporate Tax Planning Update: Mexico Module II: Corporate Tax Planning Update: Mexico 11th Annual Latin American Tax Conference Miami, Florida 10-11 March 2010 Leobardo Tenorio Tijuana Luis Adrian Jimenez Mexico City Jaime Gonzalez-Bendicksen

More information

PRACTICAL MEXICAN TAX STRATEGIES. Cross-Border Hybrid. Arrangements. Transfer Pricing Adjustments for Export Manufacturing and Maquila Taxpayers

PRACTICAL MEXICAN TAX STRATEGIES. Cross-Border Hybrid. Arrangements. Transfer Pricing Adjustments for Export Manufacturing and Maquila Taxpayers WTE PRACTICAL MEXICAN TAX STRATEGIES WorldTrade Executive Report on Tax Planning for International Companies Operating in Mexico Cross-Border Hybrid Arrangements By Juan Angel Becerra (JAB Consultores

More information

Spain Tax Alert. Broad-based corporate tax reform proposed. Tax rate. Tax-deductible expenses. International Tax. 2 July 2014

Spain Tax Alert. Broad-based corporate tax reform proposed. Tax rate. Tax-deductible expenses. International Tax. 2 July 2014 International Tax Spain Tax Alert 2 July 2014 Broad-based corporate tax reform proposed Contacts Brian Leonard bleonard@deloitte.es Francisco Martin Barrios fmartinbarrios@deloitte.es Elena Blanque elblanque@deloitte.es

More information

THE LOW INTEREST RATE ENVIRONMENT AND ITS IMPACT ON INSURANCE MARKETS. Mamiko Yokoi-Arai

THE LOW INTEREST RATE ENVIRONMENT AND ITS IMPACT ON INSURANCE MARKETS. Mamiko Yokoi-Arai THE LOW INTEREST RATE ENVIRONMENT AND ITS IMPACT ON INSURANCE MARKETS Mamiko Yokoi-Arai Current macro economic environment is of Low interest rate Low inflation and nominal wage growth Slow growth Demographic

More information

GLOBAL GUIDE TO M&A TAX

GLOBAL GUIDE TO M&A TAX 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

More information

USA Taxation. 3.1 Taxation of funds. Taxation of regulated investment companies: income tax

USA Taxation. 3.1 Taxation of funds. Taxation of regulated investment companies: income tax USA Taxation FUNDS AND FUND MANAGEMENT 2010 3.1 Taxation of funds Taxation of regulated investment companies: income tax Investment companies in the United States (US) are structured either as openend

More information

The marketing of participations in foreign private equity funds from an Austrian tax perspective

The marketing of participations in foreign private equity funds from an Austrian tax perspective Seite 1 von 6 www.altassets.net The case for countries - Austria The marketing of participations in foreign private equity funds from an Austrian tax perspective Gerald Gahleitner, Gerald Toifl, Leitner

More information

CLIENT ATTORNEY PRIVILEGED WORK PRODUCT. Jurisdictional comparison The Netherlands Luxembourg Cyprus Holding companies

CLIENT ATTORNEY PRIVILEGED WORK PRODUCT. Jurisdictional comparison The Netherlands Luxembourg Cyprus Holding companies 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

More information

International Comparison of Insurance Taxation March 2007

International Comparison of Insurance Taxation March 2007 International Comparison of Insurance International Comparison of Insurance Chile General Insurance 1 Definition Definition of property and casualty insurance company General insurance company is approved

More information

DOING BUSINESS IN GERMANY Overview on Taxation

DOING BUSINESS IN GERMANY Overview on Taxation 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

More information

Taxation of Cross-Border Mergers and Acquisitions

Taxation of Cross-Border Mergers and Acquisitions KPMG International Taxation of Cross-Border Mergers and Acquisitions Colombia kpmg.com 2 Colombia: Taxation of Cross-Border Mergers and Acquisitions Colombia Introduction Cross-border merger and acquisition

More information

U.S. Tax Structures Utilized In Connection With Foreign Investment In U.S. Real Estate. Jack Miles Kelley Drye & Warren LLP

U.S. Tax Structures Utilized In Connection With Foreign Investment In U.S. Real Estate. Jack Miles Kelley Drye & Warren LLP U.S. Tax Structures Utilized In Connection With Foreign Investment In U.S. Real Estate Jack Miles Kelley Drye & Warren LLP May 2, 2016 Topics I. Structuring Objectives II. Underlying U.S. Tax Rules --

More information

FEDERAL TAXATION OF INTERNATIONAL TRANSACTIONS

FEDERAL TAXATION OF INTERNATIONAL TRANSACTIONS 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,

More information

MEXICAN TAX BILL FOR 2016

MEXICAN TAX BILL FOR 2016 MEXICAN TAX BILL FOR 2016 On September 8, 2015, the President sent to Congress the Tax Bill where some proposals are made to change current Mexican tax legislation. The main proposals are the following:

More information

Know the Facts. Aon Hewitt Country Profiles can help: Support a decision to establish or not establish operations in a specific country.

Know the Facts. Aon Hewitt Country Profiles can help: Support a decision to establish or not establish operations in a specific country. Aon Hewitt Country Profiles Your eguide to employment requirements and practices Profiles for nearly 90 countries worldwide Risk. Reinsurance. Human Resources. Know the Facts Whether you are a newcomer

More information

Private equity investments in non-dutch targets through a Dutch Coop Jochem van der Wal / Michiel Schul

Private equity investments in non-dutch targets through a Dutch Coop Jochem van der Wal / Michiel Schul Private equity investments in non-dutch targets through a Dutch Coop Jochem van der Wal / Michiel Schul Union International des Avocats (UIA) - Tax Committee Loews Miami Beach Hotel November 3, 2011 1

More information

2.2. By whom and to which authority/authorities the application must be made? 2.3. What documents must be attached to the application?

2.2. By whom and to which authority/authorities the application must be made? 2.3. What documents must be attached to the application? IBA REAL ESTATE COMMITTEE REAL ESTATE IN A NUTSHELL: MEXICO OWNERSHIP/RESTRICTIONS ON OWNERSHIP BY NON-RESIDENTS Name: LUIS MORENO, GERARDO CARRILLO Law Firm and City/Country: HAYNES & BOONE, S.C., MEXICO

More information

Guide to Treatment of Withholding Tax Rates

Guide to Treatment of Withholding Tax Rates Guide to Treatment of Withholding Tax Rates Contents 1. Introduction 1 1.1. Aims of the Guide 1 1.2. Withholding Tax Definition 1 1.3. Double Taxation Treaties 1 1.4. Information Sources 1 1.5. Guide Upkeep

More information

Appendix 1: Full Country Rankings

Appendix 1: Full Country Rankings Appendix 1: Full Country Rankings Below please find the complete rankings of all 75 markets considered in the analysis. Rankings are broken into overall rankings and subsector rankings. Overall Renewable

More information

G E N C S V A L T E R S L A W F I R M B A L T I C T A X C A R D 2 0 1 5

G E N C S V A L T E R S L A W F I R M B A L T I C T A X C A R D 2 0 1 5 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

More information

Cross Border Tax Issues

Cross Border Tax Issues Cross Border Tax Issues By Reinhold G. Krahn December 2000 This is a general overview of the subject matter and should not be relied upon as legal advice or opinion. For specific legal advice on the information

More information

Hong Kong (Brenda Chan, Nexia Charles Mar Fan & Co, brenda@charles-marfan.com) Reviewed January 2015

Hong Kong (Brenda Chan, Nexia Charles Mar Fan & Co, brenda@charles-marfan.com) Reviewed January 2015 Hong Kong (Brenda Chan, Nexia Charles Mar Fan & Co, brenda@charles-marfan.com) Reviewed January 2015 I MAIN LEGAL FORMS Legal form Characteristics Partnership and Limited Liability Partnership (LLP) Private

More information

U.S. Taxation of Foreign Investors

U.S. Taxation of Foreign Investors U.S. Taxation of Foreign Investors By Richard S. Lehman & Associates Attorneys at Law Copyright 2004 Copyright by Richard S. Lehman Page 1 U.S. Taxation of Foreign Corporations And Nonresident Aliens General

More information

The UK as a holding company location

The UK as a holding company location 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

More information

SPANISH TAX REFORM: MAIN ISSUES FOR M&A AND FINANCING TRANSACTIONS DECEMBER 2014

SPANISH TAX REFORM: MAIN ISSUES FOR M&A AND FINANCING TRANSACTIONS DECEMBER 2014 TAX BRIEFING SPANISH TAX REFORM: MAIN ISSUES FOR M&A AND FINANCING TRANSACTIONS DECEMBER 2014 THIS BRIEFING FOCUSES ON THOSE MEASURES INCLUDED IN THE CIT ACT WHICH AFFECT M&A, FINANCING & REFINANCING TRANSACTIONS.

More information

THE MADEIRA INTERNATIONAL BUSINESS CENTRE MADEIRA COMPANY INFORMATION

THE MADEIRA INTERNATIONAL BUSINESS CENTRE MADEIRA COMPANY INFORMATION 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

More information

Tax Card 2013 With effect from 1 January 2013 Lithuania. KPMG Baltics, UAB

Tax Card 2013 With effect from 1 January 2013 Lithuania. KPMG Baltics, UAB Tax Card 2013 With effect from 1 January 2013 Lithuania KPMG Baltics, UAB CORPORATE INCOME TAX Taxable profit of Lithuanian and foreign corporate taxpayers is subject to a standard (flat) rate of 15%.

More information

Value-Added Tax Across the Latin American Region

Value-Added Tax Across the Latin American Region Value-Added Tax Across the Latin American Region 11th Annual Latin American Tax Conference The Biltmore Hotel, Coral Gables, FL 10-11 March 2010 Jose Pedro Barnola, Claudio Moretti, Alberto Maturana, Sergio

More information

Software Tax Characterization Helpdesk Quarterly April 2012

Software Tax Characterization Helpdesk Quarterly April 2012 Software Tax Characterization Helpdesk Quarterly April 2012 Characterizing foreign software revenues is a complex challenge for large and small software firms alike. Variations in the rules around the

More information

Receita Federal do Brasil (RFB) www.receita.fazenda.gov.br 1 January to 31 December Last working day of April following end of tax year

Receita Federal do Brasil (RFB) www.receita.fazenda.gov.br 1 January to 31 December Last working day of April following end of tax year Worldwide personal tax guide 2013 2014 Brazil Local Information Tax Authority Receita Federal do Brasil (RFB) Website www.receita.fazenda.gov.br Tax Year 1 January to 31 December Tax Return due date: Last

More information

Raveh Ravid & Co. CPA. November 2015

Raveh Ravid & Co. CPA. November 2015 Raveh Ravid & Co. CPA November 2015 About Us Established in 1986 by Abir Raveh, CPA & Itzhak Ravid, CPA 6 Partners, 80 employees Located in Tel Aviv, Israel wide range of professional services highly experienced

More information

Latin America. Growth in the Latin American alternative investment funds industry. Introduction. by John Salerno, Oscar Teunissen and Julian Vasquez

Latin America. Growth in the Latin American alternative investment funds industry. Introduction. by John Salerno, Oscar Teunissen and Julian Vasquez Latin America by John Salerno, Oscar Teunissen and Julian Vasquez Growth in the Latin American alternative investment funds industry Introduction The Latin American alternative investment funds industry

More information

DESCRIPTION OF THE PLAN

DESCRIPTION OF THE PLAN DESCRIPTION OF THE PLAN PURPOSE 1. What is the purpose of the Plan? The purpose of the Plan is to provide eligible record owners of common stock of the Company with a simple and convenient means of investing

More information

Comparison of Holding Regimes in Europe, Middle East and Africa

Comparison of Holding Regimes in Europe, Middle East and Africa Crowe Horwath International Comparison of Holding Regimes in Europe, Middle East and Africa As per 1 January 2013 Audit Tax Advisory www.crowehorwath.net Countries Included Albania...1 Angola...1 Austria...2

More information

Information Regarding U.S. Federal Income Tax Calculations in connection with the Acquisition of DIRECTV by AT&T

Information Regarding U.S. Federal Income Tax Calculations in connection with the Acquisition of DIRECTV by AT&T Information Regarding U.S. Federal Income Tax Calculations in connection with the Acquisition of DIRECTV by AT&T The following information is provided to illustrate how to determine taxable gain on DIRECTV

More information

Starting a Business in Israel

Starting a Business in Israel Starting a Business in Israel Inspiration Invention Innovation Content: Page 1. Business Entities....... 2 a. Company...... 2 b. Foreign Company (e.g. a branch)...... 2 c. Partnership...... 3 d. Self Employed......

More information

TAX PRACTICE GROUP Multi-Jurisdictional Survey TAX DESK BOOK

TAX PRACTICE GROUP Multi-Jurisdictional Survey TAX DESK BOOK ICELAND Introduction TAX PRACTICE GROUP Multi-Jurisdictional Survey TAX DESK BOOK CONTACT INFORMATION Ólafur Kristinsson LOGOS legal services Efstaleiti 5 108 Reykjavík Iceland +354-5400300 olafurk@logos.is

More information

Eliminating Double Taxation through Corporate Integration

Eliminating Double Taxation through Corporate Integration FISCAL FACT Feb. 2015 No. 453 Eliminating Double Taxation through Corporate Integration By Kyle Pomerleau Economist Key Findings The United States tax code places a double-tax on corporate income with

More information