Sovereign Tax Advisers’ Post

🌍 𝗝𝗼𝗶𝗻 𝘂𝘀 for an exclusive in-person training session entitled: 𝗜𝗻-𝗱𝗲𝗽𝘁𝗵 𝘂𝗽𝗱𝗮𝘁𝗲 𝗼𝗻 𝗱𝗶𝘀𝗽𝘂𝘁𝗲𝗱 𝘁𝗿𝗮𝗻𝘀𝗳𝗲𝗿 𝗽𝗿𝗶𝗰𝗶𝗻𝗴 𝗺𝗮𝘁𝘁𝗲𝗿𝘀! 🔗 𝗥𝗲𝗴𝗶𝘀𝘁𝗲𝗿 𝗵𝗲𝗿𝗲: https://buff.ly/4eNkAy2 The landscape of #tax and #transfer #pricing in Luxembourg has evolved significantly, bringing heightened uncertainty and increased risk in (inter)national tax disputes. Year after year, we witness a rise in the complexity and frequency of these issues. Our experts, comprising seasoned tax specialists and litigators, 𝘄𝗶𝗹𝗹 𝗱𝗲𝗹𝘃𝗲 𝗶𝗻𝘁𝗼 𝗰𝗿𝘂𝗰𝗶𝗮𝗹 𝘁𝗼𝗽𝗶𝗰𝘀 during our afternoon dedicated to 𝗧𝗿𝗮𝗻𝘀𝗳𝗲𝗿 𝗣𝗿𝗶𝗰𝗶𝗻𝗴. 🔍 𝗔𝗴𝗲𝗻𝗱𝗮 𝗵𝗶𝗴𝗵𝗹𝗶𝗴𝗵𝘁𝘀: ▪️ Key transfer pricing matters disputed in Luxembourg courts; ▪️ Insights into domestic case law from the perspective of tax litigators; ▪️ Cross-border transfer pricing adjustments and the mutual agreement procedure; ▪️ Updates on State aid investigations: current status and future outlook. 𝗦𝗽𝗲𝗮𝗸𝗲𝗿𝘀 𝗳𝗼𝗿 𝘁𝗵𝗶𝘀 𝘁𝗿𝗮𝗶𝗻𝗶𝗻𝗴: Antonio Alvarado Weffer, Amar Hamouche , Annie Elfassi, Andrea Addamiano, Delfina Ascoli and Marine Citton. 𝗟𝗶𝗺𝗶𝘁𝗲𝗱 𝘀𝗲𝗮𝘁𝘀 𝗮𝘃𝗮𝗶𝗹𝗮𝗯𝗹𝗲, 𝗿𝗲𝘀𝗲𝗿𝘃𝗲 𝘆𝗼𝘂𝗿𝘀 𝗻𝗼𝘄! 📅 𝗗𝗮𝘁𝗲 & 𝘁𝗶𝗺𝗲: October 10th, from 2:00 PM to 5:00 PM A welcome reception will be held at 1:30 pm. 📍 𝗟𝗼𝗰𝗮𝘁𝗶𝗼𝗻: Sofitel Luxembourg Europe Legitech Baker McKenzie Luxembourg Baker McKenzie Tax #LuxembourgTax #TaxLaw #TransferPricing #InternationalTax #Taxfromeveryangle

Congratulations to Hong Kong for being removed from the EU watchlist on tax cooperation. Similar to Hong Kong, Malaysia and Singapore were required to review and make changes to their territorial regimes to “align with international norms”. However, concerning the “disposal gain derived from the sale of equity interests”, it does not appear to be an international norm to have economic substance requirement imposed on participation exemption. Some participation exemption regimes grant 95% exemption while others grant full exemption, subject to conditions such as shareholding percentage not linked to the recipient’s economic substance. Should or can Hong Kong, Malaysia and Singapore adopt EU-style participation exemption regime and apply economic substance requirements only to disposal of portfolio investments? #economicsubstance #internationaltax #participationexemption #territorialregimes #EUwatchlist (The personal views expressed in this post do not necessarily reflect those of global EY organisation or its member firms.)

It's time for the third HK Tax Fun Fact Question! 🎉🧐 Did you know that Hong Kong has a significant number of Double Taxation Agreements (DTAs)? These agreements play a crucial role in facilitating international trade and investment by eliminating or reducing double taxation on income and capital gains. Now, here's your chance to showcase your tax knowledge and win a special prize! 🎁 Simply answer the question of the day by emailing your response, along with your full name, to [email protected]. Stay tuned for more engaging questions in the coming weeks, as we lead up to the highly anticipated IFA APAC Tax Conference. The lucky winner will be announced at the conference, where they'll be presented with their well-deserved prize. Don't miss out on this fantastic opportunity to learn, network, and showcase your expertise. Register for the IFA APAC Tax Conference today by visiting the link below: 🔗 Learn more & register for the Conference: https://lnkd.in/esXmTg5h #IFA #TaxConference #HongKongTax #DoubleTaxationAgreements #Networking #TaxExperts

Save the Date - 26 September 2024 We look forward to discussing the latest developments and controversial cases in transfer pricing assessments involving Italy and Luxembourg #crowevalente #valenteassociatigebpartners #transferpricing

𝐑𝐮𝐧𝐧𝐢𝐧𝐠 𝐚 𝐛𝐮𝐬𝐢𝐧𝐞𝐬𝐬 𝐢𝐧 𝐒𝐢𝐧𝐠𝐚𝐩𝐨𝐫𝐞? Then understanding the Corporate Income Tax (CIT) rate is key! It's the government's way of collecting tax on your company's chargeable income. But worry not, Singapore keeps things refreshingly simple. Singapore boasts a flat CIT rate of 17% on your chargeable income. This applies to both local and foreign companies, promoting a business-friendly and transparent tax system. This competitive CIT rate allows you to retain more of your profits. Reinvest these funds back into your company, fueling expansion and propelling you towards future success. This flat 17% rate applies to all companies in Singapore, regardless of size or origin. Managing your tax obligations is easy in Singapore. The Inland Revenue Authority of Singapore (IRAS) provides clear guidelines and resources to ensure smooth sailing. 👇 Click link in the comment box for clear guidelines. #Simplyfi #Singapore #Business #Tax #CIT

🌟 Client Success Story: Achieving Certificate of Resident Status in Hong Kong 🌟 We are thrilled to share our recent experience assisting a client in obtaining the "Certificate of Resident Status" for their Hong Kong company, despite their operations being offshore. This milestone is crucial for avoiding double taxation under the tax treaty, ensuring our client's business thrives globally. Hong Kong is often perceived as a tax haven, but it's so much more! The Hong Kong company 🇭🇰 and tax system provide a comprehensive set of documentation and official business proof. This setup is about "real stuff"—nothing shady here. ✅ Why Choose Hong Kong: 👉🏻 Avoid Double Taxation: The Certificate of Resident Status is essential. 👉🏻Legitimate Low Tax: Manage your global business efficiently and legally. 👉🏻Solid Documentation: Hong Kong's system offers full business proof. If you're looking to set up an offshore company to better manage your global business and enjoy low (even 0%) taxes in a legitimate way, talk to us! 📞 Get in Touch: We're here to help you navigate and succeed in the global market. www.kshkcpa.com Attached is a picture of a sample Certificate of Resident Status we obtained for a real client. #CPA #TaxPlanning #HongKong #OffshoreCompany #DoubleTaxation #TaxEfficiency

The Singapore budget came out on Friday and contained the initial details on the long-awaited Qualified Refundable Tax Credits. As a quick update, Singapore will introduce both the IIR and Domestic Top up Tax (DTT) for financial years starting on/after 1 January 2025. For the many companies here enjoying a tax incentive, this will mean a significant change in their ETR. In order to retain investment in Singapore, they have therefore announced the introduction of Refundable Investment Credits (which will be considered QRTC under the BEPS rules). Working with a similar objective as existing incentives, the RICs will be rewarded on a project-by-project basis for sizeable investments that bring “substantive economic activities” to Singapore. The total amount available for a company will be determined by either the EDB or EnterpriseSG (depending on your existing incentive). The credits will be based on expenditure with up to 50% support available for each of the relevant expenditure categories. More details available in the Summer but it's clear that companies should start planning now as they make or look to make investment decisions. #BEPS #Internationaltax #sgbudget2024 #EY

Interesting data out of Luxembourg. De facto, tax rulings that fall within the scope of Action 5 of the BEPS project are hardly used anymore. The numbers are quite different in other jurisdictions e.g. the Netherlands (299 in 2021), Singapore (156 in 2021) but also Switzerland (234 in 2021). The full peer review report for all jurisdictions is accessible here: https://lnkd.in/dgb2jZZP #BEPS #Action5 #luxembourg

I would like to extend my sincere gratitude to #ifa for giving me a great opportunity to speak at 7th IFA HK APAC International Tax Conference. I will be presenting for Workshop 7: "Latest & Hottest Tax Developments in Asia: Do you Really Know What Happens Next Door?" as a representative of South Korean jurisdiction. For those interested in any of topics to be presented at the conference, come and check it out from April 22 to 24. #IFAHK #ifa2024 #IFAHONGKONG #IFAAPAC #Koreantax #internationaltax #internationaltaxation