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Fair Tax Mark to reward tax justice

¨In this interesting article published by The Guardian and written by Craig Scott, the author discusses the relevance, pros & cos of the Tax Mark launching as a reward for transparency and fairness in corporate taxation practices and policies.¨ "In this world nothing can be said to be certain, except death...

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The Spanish Financial crisis and its source, the Spanish Saving Banks

The Spanish savings banks (SSBs) built-up excess capacity and risk concentration influenced by many stakeholders’ interests, including politicians in their decision-making bodies. SSBs were not subject to typical market discipline mechanisms, and blurred competences between the central government and the autonomous provoked the crisis of the Spanish financial system. Read...

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Balancing the Books

£2.9bn, the cumulative worth of the 92 league clubs in England and Wales for 2010/11, up 9% on the previous season. Deloitte’s Annual Review of Football Finance showed that despite the challenging economic conditions, football clubs are continuing to increase revenues and with £1.2bn paid to the treasury in Tax, football’s...

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Is Marriage a Legal Contract?

In the Volokh conspiracy blog, the question about  marriage being a contract is asked. He responded "I thought I’d respond to this on-blog because it illustrates a considerably broader point: In law, as in life, concepts like “contract” aren’t unitary things, so that either something is a contract and has all...

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Multiplication Philanthropy

Leverage is the mantra of the times in philanthropy, and rightly so. People want to know that the charities they support are using donations as effectively as possible. Donors and institutional funders are more demanding, more discerning, and less detached. They're no longer content with writing a check and securing...

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OECD launches Tax Inspectors Without Borders

10/05/2012 -  The OECD’s Task Force on Tax and Development, meeting in Cape Town, South Africa, has launched the concept of Tax Inspectors Without Borders/ Inspecteurs des impôts sans frontières – a new initiative to help developing countries bolster their domestic revenues by making their tax systems fairer and more effective. Building...

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Football Financial Future

As reported by FC Business, Football League clubs took a huge step to self sufficiency when they agreed to the implementation of Financial Fair Play (FFP) regulations last week. Based on the UEFA model, Championship clubs will have until the 2014/15 season to get their house in order or face...

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UK Tax Budget 2012

UK Tax Budget 2012 - The Association of Taxation Technicians has produced a Special Report on the March Budget in their April 2012 Newsletter. The full Report is detailed below: The contents of George Osborne’s third Budget were so well rehearsed that the real thing threatened to be an anti-climax. Was there anything left...

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Tax Evasion: Pressure to End Tax Evasion Grows as the Global Forum Publishes New Reviews

05/04/2012 - The Global Forum on Transparency and Exchange of Information for Tax Purposes has just completed peer reviews of another 11 jurisdictions. Reports on Brazil, Chile, Costa Rica, Cyprus, the Czech Republic, Guatemala, Malta, Mexico, Saint Vincent and the Grenadines and the Slovak Republic evaluate whether their national laws allow transparency and international exchange of tax information (Phase 1). The review of Korea also...

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Significant Tax Changes Announced in Spain 2012 Budget

On March 30, 2012, the Spanish government announced the 2012 budget. At the same time, the government approved Royal Decree-Law 12/2012, which introduces a number of relevant changes in the corporate tax area, including new limitations on the deductibility of interest expense. Interest-capping rule Following a trend started by other European governments,...

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Tax: OECD to Simplify Transfer Pricing Rules

According to an article published by OECD on 28.03.12, at a meeting at OECD’s first Global Forum on Transfer Pricing tax, officials from 90 countries agreed on the need to simplify transfer pricing rules, strengthen the guidelines on intangible issues and improve the efficiency of dispute resolution. Transfer pricing rules determine...

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OECD Recommends Action on International Tax Loopholes

Aggressive tax planning – untaxed income, multiple deductions and other forms of international tax arbitrage - is a growing concern for all governments. OECD’s new report Hybrid Mismatch Arrangements: Tax Policy and Compliance Issues describes arrangements that exploit national differences in the tax treatment of instruments, entities or transfers to deduct...

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Spain Supreme Court decision: Swiss principal has Spanish PE through its subsidiary in Spain

Tax Controversy and Dispute Resolution Alert Spain Supreme Court decision: Swiss principal has Spanish PE through its subsidiary in Spain Read more about the case concerning a Swiss pharmaceutical company and its Spanish subsidiary in this article published by pwc.com here:  http://www.publications.pwc.com/DisplayFile.aspx?Attachmentid=5496&Mailinstanceid=23674  ...

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Inheritance Tax business property relief on Holiday Lettings: Pawson V Inland Revenue Commissioners

The recent First Tier Tribunal decision in Pawson v Inland Revenue Commissioners granted inheritance tax business property relief to an interest in a property used for holiday lettings. The personal representatives of Nicolette Pawson, who died 20 June 2006, appealed against a determination that Mrs Pawson's 25% share in a property...

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Spain – Regional Administrative Tax Court Acknowledges the Application of EU Law over Previous Discriminatory National Law

The Madrid Regional Administrative Tax Court (known as “TEAR”) in a decision dated 29 November 2011 (notified on 27 December 2011) acknowledges the application of EU Law over previous discriminatory National Law on the treatment of EU resident pension schemes (in this particular case, a UK pension fund). In this...

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Qatar Weighs Value-Added Tax Proposal

Qatar is taking a closer look at the possibility of introducing value-added tax (VAT) along with other GCC states, suggests a key planning document. The idea is to take up the long-term challenge of broadening the revenue base and reduce the non-hydrocarbon deficit (which is the overall surplus excluding hydrocarbon revenues). Backed...

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NEW TAX AND FINANCIAL MEASURES ADOPTED BY THE SPANISH GOVERNMENT

A BRIEF SUMMARY OF THE NEW TAX AND FINANCIAL MEASURES ADOPTED BY THE SPANISH GOVERNMENT On December 30th 2011 the newly elected Spanish government approved Royal Decree 20/2011 enacting a first package of urgent tax and economic measures to correct the Spanish public deficit. Among these measures, international private clients should be...

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Asking HMRC for Advice; Inheritance Tax – Documenting Lifetime Transfers; Stamp Duty Land Tax

The following articles appeared in Tax Insider: Sleeping with the Enemy – Asking HM Revenue and Customs for Advice on Tax By James Bailey | April 2010 James Bailey points out that free advice is not always the best advice. This article is being written by request – apparently from time to time people tell the Tax...

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Mass Media, Personality Rights and European Conflict of Laws by Thomas Thiede, Colm McGrath :: SSRN

As reported by Conflicts of Law, the article critically analyses the current approach of the European Court of Justice (ECJ) alongside the proposed alternatives to a unified European conflict of laws rule dealing with the problem of cross-border infringements of personality rights. Having exposed the weakness of these approaches they...

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Qatar 2nd Easiest Country to Pay Tax Globally

Qatar’s “straight forward” tax system has been recognised worldwide with the country securing the position of “2nd easiest country to pay tax globally” in an annual report issued by PricewaterhouseCoopers, World Bank and IFC. The report titled “Paying Taxes 2012” cited the Middle East has “fewer and less complex” tax laws...

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OECD Meets with Business Commentators on the Valuation of Intangibles for Transfer Pricing Purposes

On 7-9 November 2011, delegates from Working Party No. 6’s Special Session on the Transfer Pricing Aspects of Intangibles ("WP6-TPI") met with private sector representatives to discuss definitional and ownership issues related to transfer pricing for intangibles. The agenda for the meeting, presentation material submitted by private sector participants and...

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Banks at Court

As reported by 'The Lawyer', Banks may be getting stick about how much tax they (don't) pay, but perhaps a little sympathy is in order: it sounds like their legal bills are extortionate. Between 1 July 2010 and 30 June 2011, the UK's four largest banks spent more time at court...

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Doing Business in Ireland

Our colleague Liam Rattigan, Chief Executive at Russell Brennan Keane has reminded us the benefits of using Ireland for business relocation. Please see below his message and a wealth of information.  In these challenging economic times at home and abroad, it’s easy to forget some of the positive statistics about doing...

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BRIEF SUMMARY ON THE RETURN OF SPANISH WEALTH TAX FOR 2011 AND 2012

In 2008 the Spanish Government chose to ‘eliminate’ wealth tax by applying a 100% exemption, instead of derogating the law. On 17 September 2011 the wealth tax was reintroduced by the Spanish Government as an ‘emergency economic measure’. The 100% exemption was changed to a tax free allowance of 700.000€...

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Proposal for Non-Domiciled Investors

A new tax relief for non-domiciled individuals who invest in UK business will have no upper limit and be simple to claim, a recent Government consultation document promises. In the March Budget, Chancellor George Osborne announced that from April 2012 non- domiciled individuals who are taxed on the remittance basis will...

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Tax & Environment: OECD and IEA recommend reforming fossil-fuel subsidies to improve the economy and the environment

04/10/2011 - Governments and taxpayers spent about half a trillion US dollars last year supporting the production and consumption of fossil fuels. Removing inefficient subsidies would raise national revenues and reduce greenhouse-gas emissions, according to OECD and IEA analyses. The G20 leaders in 2009 agreed to phase out subsidies that...

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UK Tax Agreement with Switzerland

The UK government has agreed measures with Switzerland to tackle offshore tax evasion. Under the terms of an agreement, existing funds held by UK taxpayers in Switzerland will be subject to a significant one-off deduction of between 19% and 34% to settle past tax liabilities. From 2013, a new withholding tax...

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How to Represent yourself in Court

Legal aid could be removed from areas such as divorce and child support if the Legal Aid bill goes through parliament. Proposed changes will remove whole areas from the scheme, leaving many people little choice but to go it alone. In a recent article by Jon Robins in the Guardian,...

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NEW CHINA BUSINESS HANDBOOK

As members of The Leading Edge Alliance, Konsilia wanst to share The China Business Handbook, a valuable new publication, produced in cooperation with the U.S. Commercial Service and LEA member firm Dezan Shira & Associates. The China Business Handbook (Second Edition) is an informative guide on starting and growing a business...

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2010 OECD Model Tax Convention, Transfer Pricing and updated PE definition

The OECD Council has approved the 2010 versions of the OECD’s Model Tax Convention, the 1995 Transfer Pricing Guidelines and the 2008 Report on the Attribution of Profits to Permanent Establishments....

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Gibraltar update on Tax Information Exchange Agreements TIEAs

The list below contains the Tax Information Exchange Agreements (TIEAs) signed by Gibraltar. Belgium-Gibraltar (16 December 2009) Iceland - Gibraltar (16 December 2009) Sweden - Gibraltar (16 December 2009) Faroes Islands - Gibraltar (20 October 2009) Finland - Gibraltar (20 October 2009) Greenland - Gibraltar (20 October 2009) Portugal -...

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