UK: Summary of Responses to Consultation on Corporate Re-domiciliation

April 13, 2022

On 12 April 2022 the UK government published a summary of the responses to the consultation on corporate re-domiciliation. The UK aims to introduce a regime to enable companies to move their domicile to, and relocated to, the UK.

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OECD: Public Consultation on Tax Transparency Framework for Crypto-Assets

March 23, 2022

On 22 March 2022 the OECD published a consultation document in relation to a global tax transparency framework for reporting crypto-assets and proposed changes to the common reporting framework for automatic exchange of financial account

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IMF: New Database on Special Purpose Entities

March 03, 2022

On 2 March 2022 the IMF announced the release of a new database on special purpose entities (SPEs) showing cross-border flows and positions of SPEs and based on an internationally agreed definition of SPEs. The release of the database follows

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UK: New Tax Regime for Asset Holding Companies

November 07, 2021

The UK budget announcements on 27 October 2021 proposed that legislation would be included in the Finance Bill 2021/22 to set up a new tax regime for qualifying asset holding companies (QAHCs). This change is part of a broader review of the UK

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India: Insolvency and Bankruptcy Code – Miles travelled but miles to go!

December 29, 2020

By Suraj Nangia, Partner and Sandeep Jhunjhunwala, Partner, Nangia Andersen LLP In an attempt to overhaul the insolvency and bankruptcy regime, India had enacted the Insolvency and Bankruptcy Code 2016 (Code) on May 28, 2016. Introduction of

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OECD: Tax relief for philanthropic entities

November 27, 2020

A report published by the OECD entitled Taxation and Philanthropy contains a detailed review of the taxation of philanthropic entities and donors in 40 countries, setting out potential policy options for countries. Reasons for giving tax

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Nigeria: President presents 2021 Budget proposals

October 16, 2020

On 8 October 2020, the President, Muhammadu Buhari, presented the Federal Budget proposals for the year 2021 at the Joint Session of the National Assembly. The recent developments in this draft Budget includes: The draft 2021 Budget, themed

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Colombia issues decree on taxation of investment funds and PEs

August 04, 2020

On 19 July 2020, the Colombia Ministry of Finance and Public Credit has issued Decree 1054 of 2020, which determines the scope in tax matters of the concepts taxation of investment funds and (permanent establishments) PEs. The Decree was issued

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Kazakhstan: New Tax Code submits to Parliament

October 09, 2017

The First Vice-Minister of National Economy, Ruslan Dalenov, submitted the draft of the new tax code to the finance and budget committee of the lower house of the Kazakh parliament (the Mazhilis) on September 21, 2017 for consideration. It was

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Canada: Finance Department announces public consultation on draft tax legislative proposals

September 14, 2017

The Finance Department released a public consultation on September 8, 2017 regarding draft legislative and regulatory proposals on the Goods and Services Tax/Harmonized Sales Tax (GST/HST) and excise duty as well as income tax. GST/HST and Excise

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OECD: Report on branch mismatch rules

July 30, 2017

On 28 July 2017 the OECD’s Committee on Fiscal Affairs (CFA) issued a document entitled Neutralising the Effects of Branch Mismatch Arrangements, Action 2. This document was issued as part of the implementation of the action plan on base erosion

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UK: New type of limited partnership

April 16, 2017

On 6 April 2017, new legislation came into force that introduces a new type of limited partnership. The Order introduces private fund limited partnerships (PFLPs) and amends the 1907 Act, which applies to PFLPs and partners in PFLPs. New and

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Japan: Tax treatment of income from U.S. limited partnerships is treated as fiscally transparent entity

February 19, 2017

On 9 February 2017, Japan’s National Tax Agency (NTA) released a report on its website confirming that a US limited partnership (US LP) is treated as fiscally transparent for Japanese tax purposes when applying the US-Japan Income Tax Treaty. The

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OECD invites comments on interaction between treaty-related BEPS provisions and treaty entitlement of non-CIV funds

January 19, 2017

A collective investment vehicle (CIV) is an arrangement that permits investors to pool their money and to purchase investments from that pooled fund rather than buying the investments directly as individuals. The report on Action 6 of the project on

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OECD: Addressing BEPS involving interest in the banking and insurance sectors

August 01, 2016

On 28 July 2016 the OECD issued a discussion draft outlining approaches to combating base erosion and profit shifting (BEPS) involving interest in the banking and insurance sectors. This is part of further work following the final report on BEPS

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Canada: LLPs established in Delaware and Florida will be treated as corporations

June 03, 2016

At the 26 May 2016 IFA International Tax Conference, the Canada Revenue Agency (CRA) has confirmed that limited liability partnerships (LLPs) and limited liability limited partnerships (LLLPs) established in Delaware and Florida are to be treated as

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OECD: Discussion draft on treaty residence of pension funds

March 02, 2016

On 29 February 2016 the OECD issued a discussion draft on the tax treaty residence of pension funds. Changes are to be made to the OECD Model to ensure that a recognized pension fund is treated for the purpose of the tax treaty as resident in the

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UK: Annual report on code of practice for banks

December 30, 2015

The Code of Practice on Taxation for Banks was published in December 2009. This voluntary Code of Practice was a non-statutory statement of principles on bank governance, openness and attitudes to tax planning. The larger financial institutions are

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