Author: Paul Ferreira, CPA President of Export Tax Management E: [email protected]

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

The IC-DISC is the most effective tax planning strategy for your clients who deliver their products for use outside of the United States. In 2017, the U.S. Congress enacted the Tax Cuts and Jobs Act of 2017. This landmark legislation provides permanence for the IC-DISC in 2018 and beyond. Many privately held companies that have products delivered to customers outside of the United States, including Canada and Mexico, are significantly reducing their US federal income taxes related to their export sales. The growing demand for U.S. products in emerging foreign markets has driven the demand for U.S.… Read More

Author: Mr. M.A. (Maxim) Boschman LL.M

Senior Manager Tax, specialized in (international) payroll taxes at Londen & Van Holland

The Dutch economy is mainly driven by human recourses (HR), knowledge and innovation. In order to attract foreign employees who bring specific knowledge to the table, the Dutch tax rules provide a favorable tax regime. This regime is called ‘the 30%-ruling’ and is applicable if certain conditions are met.

Dutch wage tax system and the 30%-ruling

In principle, everything (in money or in kind) reimbursed, given or provided to employees in that capacity is considered wage, subject to Dutch wage tax and social security contributions. Fortunately, there are certain exceptions, exemptions and benefits that could be enjoyed tax-free otherwise (e.g. have a nil-value for wage tax purposes).… Read More

Author: Nadia Oanea, CA, Tax Advisor

NOA Tax & Training SRL

The 2023 summer in Romania was a hot one, with a lot of public discussions on the need to change the tax law, to manage the increased budgetary deficit. After many proposals being discussed in mass media, on September 19, 2023, the Romanian Government published a draft law on some fiscal and budgetary measures to ensure Romania’s long-term financial sustainability. On September 26, the Government assumed responsibility in Parliament for this bill. On 27 October 2023, the Law no 296 / 2023 was published in the Official Gazette and became effective.

Some measures are foreseen to apply from November 2023, but the vast majority from 1 January 2024. What is notable, the corporate income tax due by the companies will suffer major changes starting next year.… Read More

Author: Ina Spridzane, Tax Manager, “Orients Audit & Finance” SIA

The Ministry of Finance has prepared a draft for amendments of the Law on corporate income tax for Latvia (CIT) which have been intended for credit institutions and consumer lending service providers.

Most countries use so – called standard CIT system where the tax is paid on a company’s taxable income, which includes revenue which is reduced for qualifying expenses, for instance, cost of goods sold, general and administrative expenses, selling and marketing, research and development, depreciation, and other operating costs. Thus, the taxpayers pay CIT in the period when the profit was gained.

The  system which was introduced in Latvia in 2018 is different the taxation of the profit is postponed until the profit is distributed as dividends or deemed to be distributed. … Read More

Author: Gavin Barker

VAT Director, Bright Grahame Murray

The VAT system in its various names (dependant on where you are in the world) has been adopted by 175 countries and yet it has still not been adopted by the US.

As many people will be aware, on 1st April 2023, UK VAT turned 50. Now we are part way through the designated VAT party year, I thought I would reflect on some of the history and facts about VAT in general and some of the quirky cases within the UK.

First-off a quick history lesson: The creation of VAT is widely attributed to the French civil servant Maurice Lauré in 1954, and known as Taxe sur la Valeur Ajoutée (TVA). It was originally introduced to replace the tax on production and was initially directed at large businesses.… Read More

The Brazilian Government has introduced a fresh legal framework for transfer pricing rules through Law No. 14,596/2023, effective from June 15, 2023. This move aligns Brazil’s transfer pricing (TP) rules with the Organization for Economic Cooperation and Development (OECD) standards.

Previously, Brazil’s TP rules diverged from OECD standards, often using fixed margins for TP calculations. This deviation posed challenges for multinational companies with Brazilian subsidiaries.

The updated rules apply to transactions with: (i) related parties; (ii) entities in countries that either do not tax income or tax it at a rate below 17%; and (iii) entities benefiting from a privileged tax regime.

Grounded in the arm’s length principle, for purposes of determining the Corporate Income Tax (IRPJ) and Social Contribution on Net Income (CSLL) calculation basis, the terms and conditions of a controlled transaction will be established according to those that would be established between unrelated parties in comparable transactions.… Read More

Based on recent decisions of the Independent Authority of Public Revenues in Greece, the application of a VAT exemption to imported goods under certain procedures detailed below shall no longer be granted if the declared customs value is disputed and subsequently increased by the customs authorities.

Certain categories of goods are no longer eligible for VAT exemption on import based on the procedures mentioned above. The relevant measures shall be effective as of 24.07.2023.

The procedures and types of goods to which the above decisions apply are the following:

Procedures where the new measures apply to cases where a VAT exemption is requested under a special duplicate exemption note, under a VAT warehousing procedure (“Procedure 07”), or to imported goods that are to be directly transported to another EU member state in the context of a zero-rated intra-Community supply (“Procedure 42”).… Read More

Author Grant Gilmour B.Sc. HONS , MBA, CPA BC Canada , CA, CPA Arizona USA

Recently I attended training on VAT in the UAE. That experience made me think about how different VAT programs are similar and different around the world. VAT is new in the UAE. It was implemented in 2018. Like other VAT programs around the world many questions have already come up and the UAE taxation authorities are rapidly bringing forward guidance and clarification.

Looking at Value Added Tax conceptually it is similar around the world. It is usually levied by each participant at each step of the process. I realized when studying UAE VAT that business clients are often challenged by the basics of the system and our value as advisors is often explaining these basics and the similarities and differences between different tax systems.… Read More

Author Grant Gilmour B.Sc. HONS , MBA, CPA BC Canada , CA, CPA Arizona USA

When I became editor of this newsletter, I knew many members of Integra and in particular many who are primarily tax advisors. What I am growing to know is the large “World” of tax and tax advisors that make up the Integra community.  I started to put together a list or tool to help me keep track of what firms are doing and in particular what they have on their websites regarding tax. Think of it as “speed dial” for tax advice in Integra. This is still a work in Process. I need your help to create this resource database.

Today I am asking for members to contribute their favorite resources.… Read More

Authors Chris Klug, JD, LLM Founder, Klug Counsel PLLC Tetsunori (Ted) Chiba, LLM, MST International Tax Partner,  Actus Tax Corporation

Edited By Integra International Grant Gilmour, CPA (Canada, BC) CPA (USA, Arizona)

Klug Counsel had the wonderful opportunity to collaborate with Actus Tax Corporation to provide cross-border tax representation to our now mutual client.  The Company develops solar and wind projects in Japan.  Both owners of the Company are U.S. citizens with one of the owners also being a Japanese tax resident at the time of initial representation.  The Company’s business was entering a new phase with a clean energy U.S. private equity fund investor (“PE Investor”) leading to the restructuring of the solar energy ownership structure.  Since there were Japanese tax implications, based on the location of the project, and U.S.… Read More