In this webinar session, we discussed the latest audit trends and focus areas of the cell for large enterprises, the Transfer pricing cell and the Special tax investigation office (e.g., tax treatment of reorganizations, EBITDA 30%-rule, group contribution, transfer pricing implications of financial transactions, hard-to-value intangibles, etc). We analyzed the triggers leading to a tax audit and best practices on how to best handle a tax audit. Finally, we looked ahead and discussed the impact of new regimes, such as CFC, Pillar two, the public CbCR, and multilateral tax audits.
In this session, we covered the expected implications for VAT audits going forward and gave an overview of the expected areas of focus. VAT and customs often go hand in hand, hence we also covered customs audits and investigations which are very complex and are often difficult to handle for groups due to limited compliance resources in this field. We also took this opportunity to touch upon the difficulties faced by companies regarding the different sanction packages adopted by the EU Commission and uncovered what a typical trade investigation looks like and what the focus areas are. Finally, we provided recommendations on how to best avoid an adverse outcome by implementing quality control and monitoring procedures.
Baker McKenzie’s Global Disputes Forecast 2024 reports that corporations perceive a high risk of disputes in the field of employment-related tax issues.
In this webinar, we unveiled what we think will be the areas of focus of the Belgian tax authorities, as well as the impact of the most recent case law in these areas.
On 29 December 2023, the People’s Ministry of Economy, Finance and Foreign Trade (MPPEFCE) issued Resolution No. 010-2023 (“Resolution 010“) and Resolution No. 011-2023 (“Resolution 011“) (together, “Resolutions“) establishing the rules on the organization and operation of the Superior Council for Tax Harmonization and the tables of maximum values applicable to state and municipal taxes and fees. The Resolutions were published in Official Extraordinary Gazette No. 6,783 and became effective upon its publication.
On Thursday, 7 March 2024, the Tax Subcommittee of the House Committee on Ways and Means held a hearing on the Organization for Economic Co-operation and Development (OECD) inclusive framework’s Pillar One project. The hearing marked Congress’ first public inquiry dedicated solely to Pillar One since the release of the draft Multilateral Convention to Implement Amount A of Pillar One (MLC) and the final Amount B report. The same Subcommittee examined both Pillar One and Pillar Two in a July 2023 hearing that featured then-Deputy Assistant Secretary for International Tax Affairs Michael Plowgian.
On Friday, 15 March 2024, the UAE Ministry of Finance (“UAE MoF”) issued a public consultation on the potential framework that the UAE will introduce to implement Pillar 2, the global minimum tax framework. The consultation can be accessed here: https://mof.gov.ae/global-minimum-tax-public-consultation/. The deadline to provide input into the consultation is 10 April 2024.
On 28 February 2024, Regulatory Resolution 11/2024 (“RR 11/2024”) of the Tax Agency of the Province of Buenos Aires (TABA) was published in the Official Gazette of the Province of Buenos Aires. The resolution regulates the additional advance payment (“Additional Advance Payment”) on gross income tax (GIT) established in Article 136 of Law 15,479 (Tax Law 2024), which establishes that taxpayers who comply with the parameters established in the RR 11/2024 shall pay an additional GIT advance payment equal to four times the amount of tax determined in the advance payment for the month of October 2023.
On 6 March 2024, the Chancellor of the Exchequer delivered his Spring Budget.
This contained a number of significant tax changes relevant to our clients, including changes to the way in which UK tax resident non-UK domiciled individuals will be taxed in future and a new advantageous tax regime for individuals becoming UK tax resident.
These changes are very significant and we recommend clients take immediate advice on the potential implications for them and their structures.
We’re pleased to present the 14th edition of Ukrainian Laws in Wartime: Guide for International and Domestic Businesses, a brief overview of the key features of wartime legislation. In this edition you’ll explore pertinent responses to the most common questions currently examined and addressed by international and Ukrainian businesses.
On 29 January 2024, the OECD issued the first statistics on the International Compliance Assurance Programme (ICAP). These statistics cover all 20 ICAP cases completed since the beginning of the program in 2018 through October 2023.