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
Is your upper-tier structure BEPS-proof?
The OECD BEPS Action Plan and parallel developments impact each layer of a multinational structure, including the upper tier. Specifically, having insufficient relevant substance at upper tier level could cause your return on investment to decrease significantly (by up to 25% based on the current Belgian withholding tax rate). On top, we expect that the
Impact of BEPS on M&A – Why should we care?
The OECD’s Base Erosion and Profit Shifting project (BEPS) project is the answer of the G20 to the current public debate around the use of privileged regimes. It is meant to define rules for a fairer and more equitable system of corporate income taxation. From an M&A perspective, it adds a layer of complexity and
Payments to Cyprus and Luxembourg: subject to new reporting obligation, screen your existing structures
Payments by Belgian companies of over EUR 100K (in total) to recipients in Luxembourg and Cyprus must now be reported individually in a specific form to the tax authorities. If not, they risk being non-deductible for tax purposes. Besides the additional reporting effort that this entails, it also sheds light on those payments which are
