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INTERNATIONAL TAX 
| Taxand's Take on the Year Ahead
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As the world welcomes 2013, the furore surrounding multinational tax planning is coming to a head. Governments globally have been faced with a dilemma: to balance the ongoing need to address a difficult economy through increased tax revenues, whilst conversely attempting to attract multinational investment to their shores. Tax authorities around the world are also crumbling under the weight of public pressure and may well enforce further measures to limit tax planning. Coupled with that, country competition poses a further 'hurdle' for tax harmonisation. It's a real dichotomy. So, to kick the new year off, we tour the world to understand the latest tax issues impacting your business. We explore the growing prominence of tax and provide an overview of the year ahead.
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INTERNATIONAL TAX
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| Governments are Torn Between Need for Increased Tax Receipts and Desire for Inward Investment
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The Taxand 2012 Tax Milestone Survey asked advisors from 36 countries to reveal the three most pertinent tax changes introduced in their countries during 2012. Taxand outlines key global tax trends including: Governments seeking revenues; country competitiveness; the evolution of tax legislations - transfer pricing is key; and simplification. |
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INTERNATIONAL TAX 
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| Country Competition Poses Further 'Hurdle' For Tax Harmonisation
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The debate around the taxation of multinational companies across their global markets has shown no signs of ceasing as the New Year gets underway, with politicians continuing to wake up to consumer sentiment on taxation of large corporates in their jurisdiction. 2012 saw responses at each end of the spectrum from some of the targeted multinationals, with Starbucks opting to agree annual tax payments with the UK authorities, whilst Google vehemently defended their global tax positions, emphasising the fact that they act legally within the tax structures set up by those countries in which they operate. Taxand discusses why competition for inward investment between countries is creating another hurdle for harmonisation. |
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INTERNATIONAL TAX 
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| FATCA: How Will FATCA Impact Multinationals?
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The Foreign Account Tax Compliance Act ("FATCA") was enacted in 2010 to create transparency and combat what was perceived as tax evasion by US persons holding investments in offshore accounts. The primary goal of FATCA is to allow the Internal Revenue Service ("IRS") and US Treasury to identify offshore income earned by US persons with offshore accounts or investments; and to identify US persons with non-US assets. Denmark, Mexico and the UK have since agreed concluded FACTA exchange of information agreements. Taxand investigates the impact of these developments on corporations operating globally.
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TRANSFER PRICING
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| Intangibles: Practical Considerations in Response to the OECD Guidance
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The OECD's work on intangibles in 2012 has addressed several important steps, including the issue in June of a draft revised Chapter 6 of the OECD Guidelines. This was followed by a consultation in November with representatives of organisations that submitted written comments to the draft. It was evident in the recent consultation that there is still some uncertainty regarding the content of the final version, particularly with respect to valuation methods. The changes are significant and will have a fundamental impact on the transfer pricing arrangements of groups with cross-border transactions involving intangibles. Taxand's Global Transfer Pricing team discusses these changes, and their expected impact.
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| VAT Threat on Investment Advisory Services
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In the recent GfBk Case (C-275/11), the European Court of Justice (ECJ) is analysing the VAT treatment of investment advisory services rendered to a management company of an investment fund. The issue in question is whether such services may benefit from the VAT exemption applicable to the management of investment funds. The opinion of the Advocate General, released on 8 November 2012, brings hope and is in favour of applying a VAT exemption to advisory and information services provided by a third party in relation to the management of a special investment fund, provided that the service is autonomous and continuous. Although the judgment is to be released shortly, the opinion of the Advocate General is a positive sign. Taxand's Global Indirect Tax team details this ruling and its potential impact on global organisations.
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| The Tax Management of Pension Plans - Striking the Balance
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Multinational corporations are required to participate in a large number of statutory pension plans imposed by countries with respect to employees working in their territory. Statutory coverage typically includes old age, death and disability benefits. Specific mandatory industry pension schemes may also be applicable, for example under collective bargaining agreements. In addition to required statutory coverage, additional company-specific supplementary pension benefits are widely used to provide enhanced remuneration to employees and to retain and incentivise key executives. Taxand's Global Compensation Tax team investigates the pension plans on offer in various jurisdictions, and the tax benefits of these for multinationals. |
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INTERNATIONAL TAX 
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| And Finally...
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The continuation of the global financial crisis and the threat of a triple dip recession for Europe has again led to an increasing number of strange and somewhat bizarre taxes across the world. Here's what we've discovered in 2012. |
COUNTRIES 
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| Here's your global overview of Taxand country updates. Select the country of choice to read the latest news:
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Resources
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OECD & EC Responses
Taxand Comments on OECD & EC Public Consultations and Discussion Drafts
Our tax specialists worldwide regularly provide responses to OECD discussions that inform and provide insight into key issues. See our latest responses:
Read all EC & OECD responses  |
Thought Leadership
Taxand Global Survey 2012 Research Findings View results of our second annual Taxand Global Survey: Taxand the CFO: Understanding Tax Changes as Economies Worldwide Drive Efficiency. We uncovered some fascinating insights into the key tax issues facing multinationals worldwide:
Access our key findings & download the report
Coming soon Taxand Global Transfer Pricing Intangibles Thought Leadership Report Taxand Global Energy Thought Leadership Report Discover all of our Taxand global publications  |
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Read Taxand's Take October 2012 Issue
Your regular update on the latest issues affecting multinationals
Discover more now 
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Access informed opinion on tax. Connect with our tax professionals worldwide to understand the impact of tax issues affecting multinationals today.
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General Queries If you would like to know more about any of these topics please contact our Taxand authors or your nearest Taxand advisor 
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ABOUT TAXAND
Taxand provides high quality, integrated tax advice worldwide. Our tax professionals, nearly 400 tax partners and over 2,000 tax advisors in nearly 50 countries - grasp both the fine points of tax and the broader strategic implications, helping you mitigate risk, manage your tax burden and drive the performance of your business.
We're passionate about tax. We collaborate and share knowledge, capitalising on our collective expertise to provide you with high quality, tailored advice that helps relieve the pressures associated with making complex tax decisions.
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Visit www.taxand.com to access more than 2,000 leading Taxand advisors across nearly 50 countries.
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The information contained in this document is intended only to be a guide. It must not be relied on in, or applied to, specific situations without previously seeking proper professional advice. Even though all reasonable care has been taken in its preparation, Taxand and all of its firms do not accept any liability for any errors that it may contain or lack of update before going to press, whether caused by negligence or otherwise, or for any losses, however caused, or sustained by any person. Descriptions of, or references or access to, other publications within this publication do not imply endorsement of them. As provided in the US Treasury Department Circular 230, this tax newsletter is not intended, or written by any Taxand firm, to be used, and cannot be used, by a client or any other person or entity for the purpose of avoiding tax penalties that may be imposed on any taxpayer. Taxand firms have produced this tax newsletter in connection with the marketing of our tax services relating to matters discussed therein. Each taxpayer should seek advice based on the taxpayer's particular circumstances from an independent tax advisor. Taxand is a global organisation of tax advisory firms. Each firm in each country is a separate and independent legal entity responsible for delivering client services. © Taxand Economic Interest Grouping 2013
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