Tax research & insights

International Transfer Pricing 2013/14, now in its 14th edition, is an easy-to-use reference guide covering a range of transfer pricing issues in nearly 80 countries worldwide.

4 Jun 2013 (Tue), 5pm Korea time / 4pm China time. Speakers: Henry An, Han Chon, Sangdo Lee

These alerts provide analysis of the impact of major transfer pricing, tax, and related developments within hours of the news breaking, authored by PwC professionals around the world. Each alert is classified by the country or territory to which it pertains.

A revised draft amendment to the Polish Corporate Income Tax (CIT) Act was issued by the Polish Ministry of Finance on 12 February 2013. It targets several areas where currently there is an opportunity for tax optimisation including the possibility of a tax efficient step-up in tax base value of fixed assets, in particular real estate.

The fallout from the global financial crisis and subsequent recession continues to be felt by businesses around the world, in many forms. The consequences have been wide ranging and complex, as well as difficult (if not impossible) to predict.

This PwC paper discusses a new 2015 VAT will apply to businesses that sell e-services to consumers within the European Union.

2012 was a hectic year in terms of tax developments in Spain, such as the new financial expenses capping-rule, the step-up in value of properties, the increase of tax rates, the significant and positive amendments to the SOCIMI ('Spanish REIT'), the implementation of the reverse charge rule for VAT deals, and the amended RETT rules on share deals.

The ECJ has held that investment advisory services provided to an investment management company operating a security investment fund are free of VAT as such services are deemed to be investment fund management services. The VAT exemption applies irrespective of whether the investment consultant is subject to regulation or to supervision by an authority.

A German tax bill dealing with portfolio investments is expected to be enacted in March. The bill will abolish the participation exemption for dividends received by portfolio investments after 28 February 2013.

In September 2011, the EU released a draft Directive for an EU FTT, with a planned start date of 1 January 2014. This represented the first attempt to introduce a common FTT regime across all EU countries. Since then, various countries have sought to ‘front run’ the EU FTT developments by introducing their own, domestic FTTs.

Under current German real estate transfer tax (RETT) law it is possible to indirectly acquire up to 100% of the shares in a property holding company without triggering RETT ('RETT Blocker Schemes'). In September 2012, th German Ministry of Finance presented plans for a bill to abolish the RETT Blocker Schemes.

In response to concerns regarding base erosion and profit shifting (BEPS), the Organisation for Economic Co-operation and Development (OECD) began a project to address those issues. The project, which has received significant attention, has been supported by the G20 and various individual governments.

Our free Newsalerts are designed to keep you up to date on landmark ECJ judgments and opinions, as well as EU and national developments in Europe in the field of direct taxation and state aid.

On 28 December 2012 the Spanish Official Gazette published a number of significant amendments to the domestic REIT regime (SOCIMI). The SOCIMI dates back to 2009. The economic turmoil, the severe real estate market crisis, and the stringent requirements are to be blamed for the poor record of entrants to the SOCIMI regime so far.

Our indirect tax panel discuss the business implications of the B2C 2015 VAT changes.

International Tax News is a monthly publication that offers updates and analysis on international tax developments worldwide.

TP to Go is a new mobile application from the PwC global transfer pricing network that brings the best thought leadership from the network directly to your current smart phone. TP to Go is free to download on iOS, Android, and BlackBerry.

Join us in this webcast to learn the latest trends and issues on mobilising talent into Malaysia and Vietnam and how to optimise the related tax efficiencies.

On 13 December 2012, the Luxembourg Parliament enacted (subject to confirmation by the Council of State that no second hearing is required) bill n°6497 (the “Tax Bill”), introducing new tax measures for corporations and individuals. This NewsAlert reviews only those measures that are likely to affect the real estate industry.

On 13 December 2012, the Luxembourg Parliament enacted bill n°6497 (the 'Tax Bill'), introducing new tax measures for corporations and individuals that are effective as from tax year 2013. Please refer to our last NewsAlert from Luxembourg sent in December 2012 for further details in this respect.

With an inimitable sense of timing and giving the slight feeling of a clearing of the desks before the holidays, the European Commission (EC) finally published its delegated acts (the Level 2 Regulation) under the Alternative Investment Fund Managers Directive (AIFMD) on 19 December 2012. The EU Parliament and the Council have three months to scrutinise the Regulation, but the likelihood of rejection by them seems low.

In this special edition of PwC's Perspectives, Anthony Curtis and Ogniana Todorova from PwC US take a detailed look at transfer pricing in Africa.

EU tax news is a free bimonthly newsletter with summaries of all the relevant ECJ and national court cases and decisions, and EU policy initiatives related to EU direct tax law and state aid. The newsletter is prepared by members of PwC's EU direct tax group (EUDTG) from across Europe.

Paying Taxes 2013 is a unique study from PwC, World Bank and IFC which investigates and compares tax regimes across 185 economies worldwide, ranking them according to the relative ease of paying taxes. Find out what the most common reforms are and how tax systems have changed over the last eight years.

This report looks at the challenges that companies across the world are facing as a result of stringent and diverse transfer pricing requirements.

Our Tax Controversy and Dispute Resolution alerts provide analysis on significant tax controversy issues and related developments from around the world.

Global Green Policy Insights is a bimonthly update on the latest developments in environmental taxes, regulations, and other "green" policies around the world. Written by PwC specialists around the world, they provide timely updates on new tax incentives, credits, and policy issues of interest to multinational organisations.

With analysis and insight on policy changes around the world, these bulletins help you stay up-to-date with the latest developments and explain what these changes mean for you and your business.

This publication is now part of International Tax News.

The report provides messages for companies with existing Swiss HQs which are seeking to expand their scope, assure their sustainability or reduce costs, for companies planning to implement a centralised business model but also for the Swiss authorities.

Our Tax policy Perspectives series provides insight into specific topics influencing global tax policy developments, including in-depth analysis of trends in specific jurisdiction. Drawing on case law, practical experience, and knowledge of tax systems worldwide, we'll provide a global perspective on each subject area, look at how it is currently playing out in a few contrasting territories and suggest the pivotal challenges to come.

Our tax policy trends series provides analysis and insight into the key global trends influencing the development of tax policy worldwide.

The world's taxes at a glance: rates and rules from 152 countries

A complex corporate operating model can be costly. Discover three simplification routes that could create enormous financial benefits and a flexible organisation fit for the future.

Multi-national companies are constantly looking for new ways to grow their business. Here we explore why it is critical to understand the regulatory landscape when considering a significant change to a your value chain.

International Transfer Pricing 2012, now in its 13th edition, is an easy-to-use reference guide covering a range of transfer pricing issues in over 68 countries worldwide.

Shifting the balance – from direct to indirect taxes, provides updates from key territories and regions worldwide on the development of indirect taxes and, in particular, VAT and GST regimes. Our review covers 11 countries, and provides a comparison on the changing landscape over the last 5 years .

Learn about Value Added Tax (VAT) - the world's most common form of consumption tax system - and equivalent sales tax systems implemented in 145 countries.

PwC's publication, Tax function effectiveness, is the definitive guide to the "why," the "what" and the "how" of managing an effective tax function.

Organised in a way that systematically mirrors the actual life cycle of IP rights, PwC's new book, Mastering the intellectual property life cycle, offers compelling insights from both tax and legal points of view, as well as an accounting perspective.

EU tax news is a free bimonthly newsletter with summaries of all the relevant ECJ and national court cases and decisions, and EU policy initiatives related to EU direct tax law and state aid. The newsletter is prepared by members of PwC's EU direct tax group (EUDTG) from across Europe.

PwC reports on recent changes in Real Estate Investment Trusts (REITs).

This newsletter covers international tax issues including legislative changes, case law and treaty changes.

A revised draft amendment to the Polish Corporate Income Tax (CIT) Act was issued by the Polish Ministry of Finance on 12 February 2013. It targets several areas where currently there is an opportunity for tax optimisation including the possibility of a tax efficient step-up in tax base value of fixed assets, in particular real estate.

This survey questions 30 global asset managers to see how asset managers are dealing with tax risk.

This PwC survey offers general guidance on a range of inter-company financial transactions-related transfer pricing issues and helps tax professionals navigate these complex laws in over 40 countries.

2012 was a hectic year in terms of tax developments in Spain, such as the new financial expenses capping-rule, the step-up in value of properties, the increase of tax rates, the significant and positive amendments to the SOCIMI ('Spanish REIT'), the implementation of the reverse charge rule for VAT deals, and the amended RETT rules on share deals.

The ECJ has held that investment advisory services provided to an investment management company operating a security investment fund are free of VAT as such services are deemed to be investment fund management services. The VAT exemption applies irrespective of whether the investment consultant is subject to regulation or to supervision by an authority.

A German tax bill dealing with portfolio investments is expected to be enacted in March. The bill will abolish the participation exemption for dividends received by portfolio investments after 28 February 2013.

Under current German real estate transfer tax (RETT) law it is possible to indirectly acquire up to 100% of the shares in a property holding company without triggering RETT ('RETT Blocker Schemes'). In September 2012, th German Ministry of Finance presented plans for a bill to abolish the RETT Blocker Schemes.

In response to concerns regarding base erosion and profit shifting (BEPS), the Organisation for Economic Co-operation and Development (OECD) began a project to address those issues. The project, which has received significant attention, has been supported by the G20 and various individual governments.

On 28 December 2012 the Spanish Official Gazette published a number of significant amendments to the domestic REIT regime (SOCIMI). The SOCIMI dates back to 2009. The economic turmoil, the severe real estate market crisis, and the stringent requirements are to be blamed for the poor record of entrants to the SOCIMI regime so far.

On 13 December 2012, the Luxembourg Parliament enacted (subject to confirmation by the Council of State that no second hearing is required) bill n°6497 (the “Tax Bill”), introducing new tax measures for corporations and individuals. This NewsAlert reviews only those measures that are likely to affect the real estate industry.

On 13 December 2012, the Luxembourg Parliament enacted bill n°6497 (the 'Tax Bill'), introducing new tax measures for corporations and individuals that are effective as from tax year 2013. Please refer to our last NewsAlert from Luxembourg sent in December 2012 for further details in this respect.

With an inimitable sense of timing and giving the slight feeling of a clearing of the desks before the holidays, the European Commission (EC) finally published its delegated acts (the Level 2 Regulation) under the Alternative Investment Fund Managers Directive (AIFMD) on 19 December 2012. The EU Parliament and the Council have three months to scrutinise the Regulation, but the likelihood of rejection by them seems low.