Integra Tax World

Brazilian tax reforms: a lost opportunity?

Author: Victor Serrão, CPA Partner, Pitmen Auditores Independentes W: www.pitmen.com.br E: [email protected]

Edited by: Grant Gilmour, CPA (Canada, BC) CPA (USA, Arizona) Integra Tax World Newsletter Editor E: [email protected]

 

The Brazilian tax reform, a crucial initiative to simplify and modernize the country’s tax system, is currently being processed by the National Congress. At the moment, the Chamber of Deputies is still negotiating internally the deadline to conclude the vote on the second text that complements the tax reform. Initially, the new legislation is expected to come into force in stages, between 2025 and 2033.

The reform proposes the transition from the current model, which includes taxes such as PIS, COFINS (Contribution for the Financing of Social Security), ICMS (Tax on the Circulation of Goods and Services) and IPI (Tax on Industrialized Goods), to a taxation model through the Tax on Goods and Services (IBS) and the Contribution on Goods and Services (CBS).… Read More

Taxable Income. What is that?

Author: Grant Gilmour, CPA (Canada, BC) CPA (USA, Arizona) Integra Tax World Newsletter Editor E: [email protected]

With Contributions from: Franz Schweiger, BF Consulting Austria Dr. Filip Schade, Wagemann + Partner, Germany David Lucas, Bright Grahame Murray, United Kingdom Victor Serrao, Pitmen, Brazil Wayne Soo, Fiducia LLP, Singapore

Edited by: Mark Saunders, BA FCA Chief Operating Officer Integra International E:  [email protected]

 

This is a question that tax practitioners around the world are often asked. Business owners and investors and really everyone would like the calculation of tax to be as simple as INCOME multiplied by 10 PERCENT gives TAX. And income is often reported and audited by the other “type” of accountant, the Financial Accountant. Business owners are going to ask why don’t we use the same number(s) in both cases?… Read More

Home Office Does Not Constitute Permanent Establishment for An Employer in Poland

Author: Ewa Suwińska – Licensed Tax Advisor INDEPENDENT TAX ADVISERS Warsaw, Poland E: [email protected]

 

Edited by: Grant Gilmour, B.SC., MBA, CPA BC, CA, CPA AZ Integra Tax World Newsletter Editor E:  [email protected]

 

Polish Judgement of the Voivodship Administrative Court Dated  11 June 2024

The Polish Voivodship Administrative Court (in Gliwice), in its judgment of 11 June 2024, (ref. no. I SA/Gl 914/23), addressed the issue of creation of a permanent establishment [PE] when employing staff in a home office.

The case concerned whether a German company (Company) had or did not have its Poland registered office and management at the home office of its employees in Poland. The Company has employment contracts with two Polish tax residents. They were employed as a customer a support engineer and a product manager.… Read More

VAT treatment – Cross Border Transactions inside the European Union

Author: Rakesh Ghirah LLM, Associate Partner VAT | Indirect Tax| Londen & Van Holland Amsterdam, Netherlands [email protected]

 

Edited by: Grant Gilmour, B.SC., MBA, CPA BC, CA, CPA AZ Integra Tax World Newsletter Editor E:  [email protected]

 

Based on the Value Added Tax [VAT] Directive the VAT Law in the European Union is harmonized. In principle a 0% VAT rate applies to Business to Business [B2B] transactions where goods are supplied from one Member State to another. However, this 0% VAT rate can be exploited for carousel fraud, contributing significantly to the VAT Gap in Europe, which was estimated to be around €61 billion in 2021. The VAT Gap is the estimated overall difference between the expected theoretical VAT revenue and the amount actually collected.… Read More

Be Careful When the Terms of An Acquisition Seem Too Good to be True. They Usually Are

Author: Christopher Klug BA, JD, LLM Basswood Counsel PLLC (formerly Klug Counsel PLLC) [email protected]

 

Edited by: Grant Gilmour, B.SC., MBA, CPA BC, CA, CPA AZ Integra Tax World Newsletter Editor E:  [email protected]

 

When there is a cross-border merger and acquisition there are additional complexities to plan for, typical acquisition planning in one country may be different than in another country, and the resulting tax implications can be significant.  Basswood have represented both the acquiror and target in a number of cross-border acquisitions and getting the right result requires a careful analysis of the tax implications involved.  What may seem like a very small detail may have very serious tax implications that greatly impacts the result of the acquisition for either the acquiror or target.… Read More

Attraction and Benefits of the UAE’s Corporate Tax Regime for International Businesses

Author: Gopu Rama Naidu FCA, FCCA, CPA under and Managing Partner KGRN Chartered Accountants LLC [email protected]

 

Edited by: Grant Gilmour, B.SC., MBA, CPA BC, CA, CPA AZ Integra Tax World Newsletter Editor E:  [email protected]

 

Embracing the Corporate Tax Landscape in the UAE: Opportunities for Global Business Growth

The United Arab Emirates has recently ushered in a new era of fiscal policy with the implementation of Corporate Tax, effective from the tax periods commencing on or after June 1, 2023. This move is aimed at bolstering the nation’s economic diversification and aligning its tax practices with global standards. For international businesses considering a foothold or expansion in the Middle East, the UAE’s Corporate Tax framework offers compelling incentives and a strategic advantage.… Read More

New tax provisions in 2024 for Greece

Author: George Giannopoulos Partner [email protected]

 

Edited by: Grant Gilmour, B.SC., MBA, CPA BC, CA, CPA AZ Integra Tax World Newsletter Editor E:  [email protected]

 

Law 5104/2024 (Tax Procedure Code) was published on April  20th 2024 being effective immediately.

The new Law indicates change in accounting – tax procedures and bring new procedures as well.

 

Efficiency measures

The main efficiency provisions of the Law 5104/2024 to update the Greece tax system include the following:

Pre-filled tax returns: obligation to prepare tax returns is abolished for taxpayers, who have income exclusively from wages and pensions. The tax return is automatically pre-filled by the IAPR (Independent Authority for Public Revenue) and is also automatically finalized if the taxpayer does not raise objections within the deadline for submitting the tax returns.… Read More

Tax Obligations for Related Parties – Transfer Pricing in Latin America

Originally Published in Spanish, Please look at the bottom of the article for the Spanish Version. Publicado originalmente en español, consulte la parte inferior del artículo para ver la versión en español.

 

Author: Lic. Salvador Pizano Moreno Gerente/ Manager [email protected]

Edited by: Grant Gilmour, B.SC., MBA, CPA BC, CA, CPA AZ Integra Tax World Newsletter Editor E:  [email protected]

 

Transfer pricing, an important and controllable aspect of international taxation, refers to the prices at which companies within an international corporate group transfer goods, services, or intangible assets between each other. The forward at paragraph 11 of the OECD Transfer Pricing Guides. Says

“These are the prices at which a company transfers tangible goods and intangible assets or provides services to associated companies.”… Read More

What is going on in “Good old Germany” in taxes? a Commentary

Author: By Dr. Filip Schade, Steuerberater, Master of Laws Wagemann + Partner PartG mbB, Berlin, E: [email protected]

Edited by: Grant Gilmour, B.SC., MBA, CPA BC, CA, CPA AZ Integra Tax World Newsletter Editor E:  [email protected]

 

In this article, I will give you a brief overview of the current economic situation in Germany and the reasons for this development. Following this, I will explain existing and planned tax incentives and subsidies and critically assess them. At the end of the article I will make four proposals for a more far-reaching reform of German tax law in order to make Germany attractive again as a business location for entrepreneurs and investors.

1. Current economic situation in Germany

First, I would like to say a few words about the current economic situation in Germany.… Read More

Underused Housing Tax (UHT) Canada – An Update

Author: Nicholas Raycroft, CPA Senior Manager, Tax Hendry Warren LLP | Chartered Professional Accountants E: [email protected]

 

Edited by: Grant Gilmour, B.SC., MBA, CPA BC, CA, CPA AZ Integra Tax World Newsletter Editor E:  [email protected]

 

 

On June 9, 2022, the Canadian Government enacted the “UHT Act”. This tax is intended to discourage ownership of vacant or underused Canadian real estate.  We had previously provided an overview of the new UHT in our publication on February 23, 2023 https://www.integra-international.net/underused-housing-tax-uht-canada/.

Since February 23, 2023, the Canadian Government has released additional guidance and amended UHT Act legislation. We thought it would be helpful to provide an update on some of these changes. Note that these updates are based on the amended UHT Act legislation as drafted.… Read More