Brazil: Changes to calculation basis of net equity payments and to withholding tax on interest
Here’s a link to a Tax Newsalert with respect to Brazil Taxation you may find very interesting – link This ITS Newsalert reports on Provisional Measure 694/2015, which changes the calculation basis of, and the withholding tax rates applicable to interest on, net equity payments in Brazil. Should you have any further questions on this topic
Tax reform announced in the Walloon Region
Recently, the Walloon Government announced a tax reform with respect to the “tax reduction for mortgage loans for the sole and own dwelling”. In this respect, a so-called system of “chèque habitat” would be introduced. The tax reduction would be limited in time (for maximum 20 years) and depend on the net taxable income of
Update – Netherlands – Case law on the 150 km criterion of the 30% regime
As mentioned in our headline of 27 February 2015, the European Court of Justice (‘ECJ’) issued a preliminary ruling on the question whether the 150 km criterion of the 30% regime for incoming workers is to be upheld. The ECJ was of the opinion that the 150 km criterion – in itself – does not
Update – Case law on exemption method for foreign employment income incompatible with EU Law
As mentioned in our headline of 15 July 2014, the Belgian tax authorities published a practice note (updating their position on to the attribution of personal tax benefits) after Belgium was sentenced by the European Court of Justice for breaching EU law. The relevant judgement indicated that EU law is violated where a taxpayer cannot
EU Commission’s final decisions in Starbucks and Fiat state aid cases
On 21 October 2015, the European Commission decided that Luxembourg and the Netherlands have granted selective tax advantages to Fiat Finance and Trade and Starbucks, respectively. These are illegal under EU state aid rules. For more information on the key aspects of the investigation and its impact, please have a look at our news alert.
Allocation of acquisition debt: economic rationale is key!
In today’s tax world, having a strong economic rationale to support an entity’s leverage is key. In our recent experience, the tax authorities look at a company’s gearing in 3 ways: Business purpose test: what is the motivation for each entity taking a loan? TP principles: Is the interest rate at arm’s length considering the
Tax reform announced in the Brussels Region
The Brussels Capital Region has recently presented its budget for 2016. Amongst others, a tax reform was announced, which will be implemented partially in 2016 and partially in 2017. In 2016, the lump-sum regional tax of EUR 89 and the additional levy of 1% on the federal personal income taxes will be abolished. Real estate
FASB redeliberates two proposed Accounting Standards Updates
During the 5 October 2015 Board meeting, the Financial Accounting Standards Board (‘FASB’) discussed external feedback received and began redeliberations on two proposed ASU’s: Income Taxes (Topic 740): Intra-Entity Asset Transfers, and Income Taxes (Topic 740): Balance Sheet Classification of Deferred Taxes. In evaluating the intra-entity asset transfers topic, the Board asked the staff to
