Organizational and Tax Issues in Managing Global Treasury. Demands of Managing a Global Treasury
|
|
- Alfred Clarke
- 6 years ago
- Views:
Transcription
1 Organizational and Tax Issues in Managing Global Treasury Global Cash Management Ltd. Grant Thornton International Demands of Managing a Global Treasury Managing Treasury on a global basis requires a tax driven focus in order to set up the most effective structure for managing liquidity and risk worldwide.. Grant Thornton International 1 1
2 Objectives for Today Today we will cover selected treasury issues and the related tax implications with a specific focus on: Structure Liquidity & Risk Management Grant Thornton International 2 STRUCTURE Grant Thornton International 3 2
3 Structure Operational Framework Present situation => requirements Setting Up key tax considerations How, options & issues Centralized vs. Decentralized Treasury Definitions, locations & activities Reporting Tax & Treasury Issues Grant Thornton International 4 Operational Framework Numerous overseas operations Sales offices Manufacturing facilities Warehousing & distribution centers Joint ventures Requirements Further centralize liquidity & risk management Address reporting & information needs Grant Thornton International 5 3
4 Operational Framework Branch? Sub? Reporting? Locations Organization Holding Co.? Tax regime? Treaties? Offshore Finance Co.? Banking Needs? Treasury Center Grant Thornton International 6 Setting Up - Tax Considerations & Options Tax structure is key before treasury planning can take place. Holding Company? Joint Ventures? Subsidiary? Branch? Local Tax jurisdictions? Grant Thornton International 7 4
5 Branch vs. Subsidiary? US-MNC Profits immediately taxable in US Deferral Branch Office Primarily sales; Usually smaller Subsidiary local taxation; Manufacturing etc. Grant Thornton International 8 Holding Companies/Joint Ventures Holding Companies Tax consolidation Domestic vs. cross border Banking efficiencies Joint Ventures Corporate vs. non Corporate Control issues => Treasury Credit exposure Grant Thornton International 9 5
6 Local Tax Jurisdictions Capitalization requirements Entity selection Corporate tax regime Treaties in place Repatriation Withholding tax issues Grant Thornton International 10 Centralized vs. Decentralized Treasury Definitions What does centralized really mean? Location(s) US only Regional Treasuries Activities Tax consequences Grant Thornton International 11 6
7 Definitions (1) A Centralized Treasury should have: Oversight responsibility for all global banking Interface and coordination with corporate tax Centrally developed guidelines and procedures for local borrowing & investments FX policy in place Grant Thornton International 12 Definitions (2) A Centralized Treasury may have: Centralized liquidity and risk management Regional Treasury operations Decentralized day-to-day cash management Local collections & disbursements Dotted line reporting only Grant Thornton International 13 7
8 Stages of Treasury Centralization Treasury Center or Corp Level 2. TC or Corp interface with markets Invest/Borrow 3. TC takes on A/P transactions Disburse Invest/Borrow 4. All purchase, distribution, A/R etc. at central level Collect/Disburse Invest & Borrow Decentralized Centralized Liquidity Fully Centralized Collect/Disburse Invest & Borrow 1. All sales, purchasing and sub level Collect/Disburse 2. Subs still manage operations Collect 3. Sub collects, but all excess can go to TC Sales only Subsidiary Level 4. Only good for simple product sales, no manufacturing Grant Thornton International 14 Locations - US-based Treasury Only Organization/reporting Regional responsibilities Infrastructure in place Reporting lines clearly defined Treasury Center Offsetting FX gains/losses Tax implications Grant Thornton International 15 8
9 Locations Regional Treasuries Existing overseas operation(s) Major manufacturing location Management/marketing center Warehouse/distribution point Finance Company or specific tax structure Tax jurisdiction/implications Charging structure - restrictions Substance capitalization Grant Thornton International 16 Oversight/consulting Intercompany netting Liquidity management Financing Investing FX trading Tax implications Management fees? Transfer pricing Activities Grant Thornton International 17 9
10 Reporting Treasury Issues Treasury Issues Direct vs. dotted line Rare to have direct reporting from foreign subsidiaries to Treasury Political considerations Information requirements Frequency Level of detail Grant Thornton International 18 Reporting Tax Issues Deferral vs. Consolidation Functional currency The reporting package central vs. decentralized access points US GAAP vs. US tax GAAP vs. Foreign GAAP Check the box options Subpart F anti-deferral issues US earnings and profits issues Grant Thornton International 19 10
11 Liquidity & Risk Management Grant Thornton International 20 Liquidity & Risk Management Financing Investing Intercompany Cash Flows Specialized Treasury Vehicles and Arrangements FX Risk Management Grant Thornton International 21 11
12 Financing (1) Funding foreign operations Debt vs. Equity financing Thin capitalization issues Is interest deferred or lost under thin capitalization restriction? Is interest on cash or accrual on related party debt? Withholding tax issues Grant Thornton International 22 Financing (2) Access to credit markets and costs Use of overdraft lines Impact on centralized debt facilities and loan covenants Offset between surplus and deficit positions Notional pooling vs. ZBAs Tax implications Grant Thornton International 23 12
13 Financing (3) Interest on related party debt Parental guarantees Arm s Length Requirement 956 issue (deemed dividends) 90 day grace period Grant Thornton International 24 Investing Mechanics Banking arrangements/costs Locations Withholding tax/reserve requirements Currencies and FX management Interest Subpart F High tax kickout Grant Thornton International 25 13
14 Intercompany Flows (1) Intercompany sales & payables Terms 90 day rule Opportunities for liquidity & risk management Opportunities for bilateral offset or multilateral netting? Transfer pricing - strategies Pricing in relation to - Goods or services Leases or licenses Debt? Grant Thornton International 26 Intercompany Flows (2) Dividends Rate averaging between high/low rate countries To the US To intermediate foreign holding companies Deductions of dividends vs. interest Dividend imputation systems Split rate systems and the dividend issue Withholding tax Subpart F implications Grant Thornton International 27 14
15 Intercompany Flows (3) Foreign Tax Credits Withholding taxes and the direct foreign tax credit Indirect foreign tax credit The global foreign tax credit limitation baskets Required expense allocations and apportionments Excess foreign tax credit positions Grant Thornton International 28 Intercompany Flows (4) Subpart F Implications of intermediate dividend receiving holding companies Subpart F high tax kickout exception for dividends Subpart F same country exception for dividends 956A in intercompany pooling/centralized offshore investing Grant Thornton International 29 15
16 Specialized Vehicles Financing companies Use of B.Vs Offshore Trading companies Offshore Treasury Center Coordination centers IFSC Dublin Docks Licensing companies Commissionaire arrangement Grant Thornton International 30 Offshore Finance Companies US-MNC Foreign subs Lend Lend Direct access = w/h tax & Income tax disadvantages Borrow Offshore Finance Co. Borrow Non domestic Financing Sources In right location no w/h tax on interest (i.e - B.V.) Grant Thornton International 31 16
17 Offshore Trading Company Exporter pay invoice Ship goods Trading Company invoice Importer pay Grant Thornton International 32 Offshore Treasury Center Ability to defer TC profits from US tax; 0/low tax on interest US - MNC Favorable Tax Regime Foreign Op. units Treasury Center IFSC Consolidation of FX +/- at the TC BCC BV SAFI OHQ Grant Thornton International 33 17
18 Licensing Companies MNC (Licensor) pay license Licensing Company license Licensee pay Grant Thornton International 34 Commissionaire Arrangements * to local a/c or a/c in TC bank location Local Customer 3) Ship/title passes Treasury Center or Warehouse 4)Pay direct to TC/WH* 6) pay local expenses 1) Sale 2) Order Local Sub 5) Commission on sale Grant Thornton International 35 18
19 FX Risk Management Determine functional currency (FC) of foreign business units Type of business activity (i.e. manufacturing for export) Country high inflationary environment? FC changes and changes in accounting method Grant Thornton International 36 FX Risk Management Tax View Translation exposure Can trigger FX +/- when funds are remitted Remittances Foreign Branch US Parent No translation exposure Dividends are at Spot rate, no FX +/_ Dividends Foreign Sub Assume FC is non USD Grant Thornton International 37 19
20 FX Risk Management Tax View FX gains & losses Mark to market - US vs. Foreign jurisdiction Passive vs. Active - the underlying transaction Qualified foreign hedging exception (subpart F issues) Qualified foreign hedging exception with US corporations Foreign subsidiaries & the active business needs exception Foreign tax credit limitations The P&L method vs. DASTM (net worth) method Grant Thornton International 38 FX Risk Management Treasury View Parent Co Translation exposure Parent Co Transaction Exposure US Parent Business Unit Transaction Exposure Foreign Business Units receivable payable Assume FC is non USD 3 rd party vendor or customer Assume non Business unit currency Grant Thornton International 39 20
21 FX Risk Management Treasury View Protect profit/shareholder value Natural offsets Policy & Procedures Accountability Hedging Objectives/philosophy Centralizing risk Mechanics Offset of FX +/- Grant Thornton International 40 Treasury Summary + Tax Grant Thornton International 41 21
22 Summary Tax planning impacts how Treasury will Manage cash flows Structure financing & credit facilities Interface with foreign operations Ongoing coordination with tax ensures Logical set up of specialized vehicles Tax effective solutions for liquidity management challenges Grant Thornton International 42 22
FDU: U.S. International Corporate Tax
93 Foreign Tax Credit 94 Foreign Tax Credit Credit allowed for foreign income taxes Limited to portion of current year tax generated by foreign source taxable income Excess credits carried over Back 1
More informationCHINA GLOBAL GUIDE TO M&A TAX: 2017 EDITION
CHINA 1 CHINA INTERNATIONAL DEVELOPMENTS 1. WHAT ARE RECENT TAX DEVELOPMENTS IN YOUR COUNTRY WHICH ARE RELEVANT FOR M&A DEALS AND PRIVATE EQUITY? A couple of tax circulars have been released by the State
More informationInternational Tax Korea Highlights 2018
International Tax Korea Highlights 2018 Investment basics: Currency South Korean Won (KRW) Foreign exchange control Controls exist, but gradually have been liberalized. Foreign loans in excess of a specified
More informationFX Regulations in Korea
FX Regulations in Korea Deutsche Bank Corporate Banking Coverage Mari Namihira CBC Asia/Europe regional call Cash Management-related Regulations Outgoing Overseas Payments Amount below 1,000 USD (or equivalent):
More informationBasic International Taxation
Basic International Taxation Roy Rohatgi KLUWER LAW INTERNATIONAL LONDON / THE HAGUE / NEW YORK TABLE OF CONTENTS Preface About the Author xiii xv CHAPTER 1 AN OVERVIEW OF INTERNATIONAL TAXATION 1 1. Objectives
More informationChapter 24. Taxation of International Transactions. Eugene Willis, William H. Hoffman, Jr., David M. Maloney and William A. Raabe
Chapter 24 Taxation of International Transactions Eugene Willis, William H. Hoffman, Jr., David M. Maloney and William A. Raabe Copyright 2004 South-Western/Thomson Learning Overview Of International Taxation
More informationSilicon Valley Chapter
Silicon Valley Chapter Subpart F: Legislative Update Review and Planning Strategies March 23, 2017 Biltmore Hotel & Suites, Santa Clara Lowell D. Yoder lyoder@mwe.com Tax Reform Proposals President Trump
More informationTerritoriality for the United States? Panelists
Territoriality for the United States? American Bar Association, Section of Taxation, Committee on Foreign Activities of United States Taxpayers May 6, 2011 1 Panelists [TBD], U.S. Treasury Department Jeff
More informationFDU: U.S. International Corporate Tax
190 Controlled Foreign Corporations 191 CFCs: Introduction Subpart F designed to prevent deferral of portable income Applies to US Shareholders of Controlled Foreign Corporations earning Subpart F income
More informationInternational Tax Egypt Highlights 2018
International Tax Egypt Highlights 2018 Investment basics: Currency Egyptian Pound (EGP) Foreign exchange control Following the floatation of the EGP on 3 November 2016, the central bank relaxed some restrictions
More informationTax Issues for Outbound Investors. Marie Bradley Bradley Tax Consulting
Tax Issues for Outbound Investors Marie Bradley Bradley Tax Consulting Date: 20 th September 2011 Introduction Developing economies, rapid pace of growth Shift in world GDP towards emerging markets Large
More informationTreasury and US Tax Reform 1
Treasury and US Tax Reform 1. Introduction The 2017 tax law provides the first major changes to the US tax code in over 30 years and it has important implications for multinational companies. The most
More informationAHLA. A. The Globalization of Health Care Opportunities and Potential Pitfalls. Michael Domanski Honigman Miller Schwartz and Cohn LLP Detroit, MI
AHLA A. The Globalization of Health Care Opportunities and Potential Pitfalls Michael Domanski Honigman Miller Schwartz and Cohn LLP Detroit, MI Timothy A. A. Stiles KPMG LLP New York, NY Tax Issues for
More informationChanges Abound in New Tax Bill for Multinational Companies
News Changes Abound in New Tax Bill for Multinational Companies 01.08.2018 Perhaps some of the most extensive changes in H.R. 1, known as the Tax Cuts and Jobs Act (the Act ), deal with the taxation of
More informationQUESTIONNAIRE ON THE TREATMENT OF INTEREST PAYMENTS AND RELATED TAX BASE EROSION ISSUES
QUESTIONNAIRE ON THE TREATMENT OF INTEREST PAYMENTS AND RELATED TAX BASE EROSION ISSUES This questionnaire should be completed by participants in United Nations capacity development programs on protecting
More informationMineral Policy for Mozambique. Robert Conrad
Mineral Policy for Mozambique Robert Conrad Current Fiscal Regime for Mining Item Description Tax Incentives Customs duties and VAT Exemptions for equipment: exempt for temporary import of necessary equipment
More informationTax Executives Institute Houston Chapter Advanced ASC 740 International Tax Issues. May 4, Ernesto Galvan and Karen Hoffman PwC Houston
Tax Executives Institute Houston Chapter Advanced ASC 740 International Tax Issues May 4, 2016 Ernesto Galvan and Karen Hoffman Houston Ernesto Galvan Partner International Tax Services Group, PricewaterhouseCoopers
More informationInternational Tax Primer Andrew D. Oppenheimer, Esq. October 31, 2017
International Tax Primer Andrew D. Oppenheimer, Esq. October 31, 2017 Agenda International tax concepts Taxation of foreign earnings Sourcing of income and expenses Foreign tax credits Subpart F income
More informationInternational Tax Argentina Highlights 2018
International Tax Argentina Highlights 2018 Investment basics: Currency Argentine Peso (ARS) Foreign exchange control Argentina operates a limited foreign exchange control regime. The transfer of funds
More informationNRWT: Related party and branch lending
April 2017 (upd 16 April 2017) A special report from Policy and Strategy, Inland Revenue : Related party and branch lending The Taxation (Annual Rates for 2016 17, Closely Held Companies, and Remedial
More informationU.S. Tax Reform. 33 rd Annual TEI-SJSU High Tech Tax Institute November 14, 2017
U.S. Tax Reform 33 rd Annual TEI-SJSU High Tech Tax Institute November 14, 2017 David Forst, Partner Fenwick & West LLP Nathan Giesselman, Partner Skadden, Arps, Slate, Meagher & Flom LLP Sajeev Sidher,
More informationInternational Tax Colombia Highlights 2018
International Tax Colombia Highlights 2018 Investment basics: Currency Colombian Peso (COP) Foreign exchange control Foreign exchange that is to be used for foreign direct investment may enter the country
More informationExercises. Copyright Stephen C. Fox, FDU, Fall, Copyright Stephen C. Fox,
Exercises 147 Interest Apportionment» Reg. 1.861-8 thru 12 Consolidated return interest expense apportioned based on consolidated return assets 3 methods: tax basis, AMT basis, FMV Apportion to all baskets
More informationTable of Contents. Part I La Brienza Winery: Tax Trouble in Wine Country. Chapter 1 Introduction: The Vital Role of Tax in Global Management
Table of Contents Part I La Brienza Winery: Tax Trouble in Wine Country Chapter 1 Introduction: The Vital Role of Tax in Global Management La Brienza Winery, Present Day...3 The Two Objectives of International
More informationCross-border Outsourcing
1 st Subject IFA Mumbai October 2014 Cross-border Outsourcing Issues, Strategies & Solutions Natalie Reypens, partner Loyens & Loeff IFA Belgium 15 October 2013 Content 1. Introduction 2. Domestic law
More information23 rd Annual Health Sciences Tax Conference
23 rd Annual Health Sciences Tax Conference Treasury tax issues for life sciences companies December 9, 2013 Disclaimer EY refers to the global organization, and may refer to one or more, of the member
More informationMexico. Investment basics
Mexico Josemaria Cabanillas Director Tel: +1 718 508 6804 jmcabanillas@deloitte.com Eduardo Rueda Senior Manager Tel: +1 212 492 4765 eruedaherrera@deloitte.com Investment basics Currency Mexican Peso
More informationTaxation of cross-border mergers and acquisitions
Taxation of cross-border mergers and acquisitions Canada kpmg.com/tax KPMG International Taxation of cross-border mergers and acquisitions a Canada Introduction Although not defined by statute, the phrase
More informationIntercompany financing facing new challenges. EY Africa Tax Conference September 2014
Intercompany financing facing new challenges EY Africa Tax Conference September 2014 Panel Moderator Ide Louw International Tax EY South Africa Panel Joseph Pagop Noupoue EY Jemimah Mugo EY Kenya Michael
More informationTax Structuring for Canadian Investment in Latin American Mining Projects
Tax Structuring for Canadian Investment in Latin American Mining Projects Steve Suarez, Borden Ladner Gervais LLP Michael Colborne, Thorsteinssons LLP Rocky Mineral Law Foundation Special Institute on
More informationUS tax reform: A sea change for international taxation The Dbriefs Tax Reform series
US tax reform: A sea change for international taxation The Dbriefs Tax Reform series Todd Izzo, Partner, Deloitte Tax LLP Rochelle Kleczynski, Partner, Deloitte Tax LLP Chris Trump, Principal, Deloitte
More informationInternational Tax Taiwan Highlights 2018
International Tax Taiwan Highlights 2018 Investment basics: Currency Taiwan Dollar (NTD) Foreign exchange control Foreign exchange transactions are administered by the central bank. A limit of USD 50 million
More informationNEW ZEALAND. Country M&A Team Country Leader ~ Peter Boyce Arun David Declan Mordaunt Todd Stevens David Rhodes Eleanor Ward Mark Russell Peter J Vial
171 PricewaterhouseCoopers NEW ZEALAND Country M&A Team Country Leader ~ Peter Boyce Arun David Declan Mordaunt Todd Stevens David Rhodes Eleanor Ward Mark Russell Peter J Vial 172 PricewaterhouseCoopers
More informationInternational Tax Japan Highlights 2019
International Tax Updated January 2019 Recent developments: For the latest tax developments relating to Japan, see Deloitte tax@hand. Investment basics: Currency Japanese Yen (JPY) Foreign exchange control
More informationSENATE TAX REFORM PROPOSAL INTERNATIONAL
The following chart sets forth some of the international tax provisions in the Senate Finance Committee s version of the Tax Cuts and Jobs Act bill, as approved by the Senate Finance Committee on November
More informationCHOICE OF ENTITY FOR INTERNATIONAL OPERATIONS AFTER THE 2017 TAXACT
CHOICE OF ENTITY FOR INTERNATIONAL OPERATIONS AFTER THE 2017 TAXACT John R. Wilson Partner, Holland & Hart LLP Holland & Hart Denver Tax Conference December 5, 2018 Copyright 2018 by John R. Wilson INBOUND
More informationCOPYRIGHTED MATERIAL U.S. ACCOUNTING REQUIREMENTS HIGHLIGHTS FASB 52: REQUIREMENTS OVERVIEW
HIGHLIGHTS 1 U.S. ACCOUNTING REQUIREMENTS FASB 52 Requirements Overview FASB 52 Currency Exchange Rates FASB 52 Currency Translation Organizational Impacts FASB 52: REQUIREMENTS OVERVIEW The Financial
More informationU.S. Investment into Brazil: Planning to Avoid the U.S. Anti-Deferral Rules
U.S. Investment into Brazil: Planning to Avoid the U.S. Anti-Deferral Rules Presented by: Jeffrey Rubinger #10887549_2.pptx 1 Basic Rules of Subpart F Certain income of a controlled foreign corporation
More informationCONFERENCE AGREEMENT PROPOSAL INTERNATIONAL
The following chart sets forth some of the international tax provisions in the Conference Agreement version of the Tax Cuts and Jobs Act, as made available on December 15, 2017. This chart highlights only
More informationComprehensive Reform of the U.S. International Tax System The NY State Bar Association Tax Section Annual Meeting
Comprehensive Reform of the U.S. International Tax System The NY State Bar Association Tax Section Annual Meeting Chair: Kathleen L. Ferrell, Davis Polk & Wardwell LLP Michael J. Caballero, Covington &
More informationPlenary: global trends impacting international tax planning and a US tax update
Plenary: global trends impacting international tax planning and a US tax update Tom Calianese, Ernst & Young LLP James Sauer, Ernst & Young LLP Gerrit Groen, Ernst & Young LLP Disclaimer Ernst & Young
More informationU.S. tax reforms prevention of base erosion. S. Krishnan
U.S. tax reforms prevention of base erosion S. Krishnan 2 U.S. tax regime prior to 2018 Amongst the large economies in the world, the United States had the highest statutory corporate income tax rate upwards
More informationInternational Tax New Zealand Highlights 2019
International Tax Updated January 2019 Recent developments For the latest tax developments relating to New Zealand, see Deloitte tax@hand. Investment basics: Currency New Zealand Dollar (NZD) Foreign exchange
More informationInternational Tax Turkey Highlights 2018
International Tax Turkey Highlights 2018 Investment basics: Currency Turkish Lira (TRY) Foreign exchange control The TRY is fully convertible, at least from the Turkish side, to the extent Turkey is recognized
More informationTaxation of cross-border mergers and acquisitions
Taxation of cross-border mergers and acquisitions Mexico kpmg.com/tax KPMG International Mexico Introduction Foreign investment in Mexico by multinationals has substantially increased over the past decade,
More informationTaxation of International Transactions
Taxation of International Transactions General Tax Provisions US Individuals Gross Income Business Deductions Personal Deductions Personal Exemptions = Taxable Income X Tax Rates (about 40%) = Basic Tax
More informationSENATE TAX REFORM PROPOSAL INTERNATIONAL
The following chart sets forth some of the international tax provisions in the Senate s version of the Tax Cuts and Jobs Act, as approved by the Senate on December 2, 2017. This chart highlights only some
More informationWELCOME TO OUR WEBINAR
WELCOME TO OUR WEBINAR International Franchise Structures Tuesday, September 15, 2015 1:00 p.m. EDT If you cannot hear us speaking, please make sure you have called into the teleconference number on your
More informationInternational Tax. Environments. Chapter Outline. Tax Neutrality INTERNATIONAL INTERNATIONAL FINANCIAL MANAGEMENT FINANCIAL MANAGEMENT
INTERNATIONAL FINANCIAL MANAGEMENT Fourth Edition EUN / RESNICK International Tax Environment 21 Chapter Twenty-one INTERNATIONAL Chapter Objective: FINANCIAL MANAGEMENT This chapter provides a brief introduction
More informationInternational Tax Taiwan Highlights 2019
International Tax Updated January 2019 Recent developments: For the latest tax developments relating to Taiwan, see Deloitte tax@hand. Investment basics: Currency Taiwan Dollar (NTD) Foreign exchange control
More informationInternational tax analytics- Unlocking value through identification and management of critical tax attributes
International tax analytics- Unlocking value through identification and management of critical tax attributes Original Publication Date: November 2nd, 2017 CPE Credit is not available for viewing archived
More information11th Annual Domestic Tax Conference. 17 May 2016 Chicago
11th Annual Domestic Tax Conference 17 May 2016 Chicago Current issues in Treasury risk management Disclaimer EY refers to the global organization, and may refer to one or more, of the member firms of
More informationInternational Tax Greece Highlights 2018
International Tax Greece Highlights 2018 Investment basics: Currency Euro (EUR) Foreign exchange control Capital controls are in force and certain limitations still apply on bank withdrawals and bank transfers
More informationWhat Entity Do You Want To Be?
What Entity Do You Want To Be? Presenters: Carla M. Smaston, Plante Moran Chip Chambley, Dixon Hughes Goodman, LLP Agenda I. Choice of Entity for Foreign Operations Overview of U.S. System Tax Classifications
More informationInternational Tax Japan Highlights 2018
International Tax Japan Highlights 2018 Investment basics: Currency Japanese Yen (JPY) Foreign exchange control There are no controls, but some reporting requirements apply. Accounting principles/financial
More informationTransfer Pricing Country Summary Turkey
Page 1 of 8 Transfer Pricing Country Summary Turkey August 2018 Page 2 of 8 Legislation Existence of Transfer Pricing Laws/Guidelines Formal transfer pricing rules were introduced in Turkey on 21 June
More informationInternational Tax Ireland Highlights 2018
International Tax Ireland Highlights 2018 Investment basics: Currency Euro (EUR) Foreign exchange control None, and no restrictions are imposed on the import or export of capital. Repatriation payments
More informationWhat s New in the 2016 US Model Treaty?
What s New in the 2016 US Model Treaty? Panelists: Lori Hellkamp, Jones Day Danielle Rolfes, U.S. Treasury Department David G. Shapiro, Saul Ewing LLP Gretchen Sierra, Deloitte Tax LLP Jason Yen, U.S.
More informationForeign Exchange Controls and Efficient Cash Management
Foreign Exchange Controls and Efficient Cash Management A view from the Tax Department 2016 Latin America Tax Summit, Rio de Janeiro 29 February to 2 March Foreign Exchange Controls and Efficient Cash
More informationInternational Tax Greece Highlights 2019
International Tax Updated January 2019 Recent developments: For the latest tax developments relating to Greece, see Deloitte tax@hand. Investment basics: Currency Euro (EUR) Foreign exchange control Restrictions
More informationTaxation of cross-border mergers and acquisitions
Taxation of cross-border mergers and acquisitions Iceland kpmg.com/tax KPMG International Iceland Introduction An Icelandic business enterprise may be organized as a limited liability company: either
More informationInternational Tax Poland Highlights 2018
International Tax Poland Highlights 2018 Investment basics: Currency Polish Zloty (PLN) Foreign exchange control None (generally) for transactions with EU, EEA, OECD and some other countries. Permission
More informationInternational Tax Reporting and Opportunities
International Tax Reporting and Opportunities Justin Hobson May 16, 2017 2017 Lane Powell PC 1 Agenda 1. Objective 2. Acronyms 3. Common Outbound Structures 4. Common Inbound Structures 5. Current Tax
More informationInternational Tax & the TCJA for Strategic Alliance Firms
International Tax & the TCJA for Strategic Alliance Firms MAY 22, 2018 TO RECEIVE CPE CREDIT Individuals Participate in entire webinar Answer polls when they are provided Groups Group leader is the person
More informationPrinciples of International Tax Planning
Overview and Learning Objectives This course is aimed at analysing the fundamentals of international tax planning in a structured and consistent manner, deepening the knowledge of tax planning techniques
More informationSession 4, Module Three:
Chapter 8: Introduction to Working Capital Management Session 4, Module Three: Working Capital Management v4.0 2013 Association for Financial Professionals. All rights reserved. Session 4: Module 3, Chapter
More informationTreasury Priorities 2014: Cautious Optimism
Citi Treasury & Trade Solutions Liquidity Management Services January 14, 2014 Treasury Priorities 2014: Cautious Optimism 2014 Citibank, N.A. All rights reserved Please email any questions you may have
More informationPlanning with the New FTC Baskets
Planning with the New FTC Baskets 2018 U.S. Cross-Border Tax Conference May 15 17, 2018 kpmg.com Agenda 01 Significant Tax Reform changes to FTC rules - New FTC baskets and FTC limitation - Deemed paid
More informationInternational Income Taxation Chapter 13: DIRECT INVESTMENT ABROAD
Presentation: International Income Taxation Chapter 13: DIRECT INVESTMENT ABROAD Professors Wells April 23, 2014 Chapter 13 Direct Investment Abroad p. 1073 Alternative foreign investment situations: Cf.,
More informationInternational Tax Italy Highlights 2018
International Tax Italy Highlights 2018 Investment basics: Currency Euro (EUR) Foreign exchange control There are no foreign exchange controls or restrictions on repatriating funds. Residents and nonresidents
More informationTECHNICAL EXPLANATION OF THE SENATE COMMITTEE ON FINANCE CHAIRMAN S STAFF DISCUSSION DRAFT OF PROVISIONS TO REFORM INTERNATIONAL BUSINESS TAXATION
TECHNICAL EXPLANATION OF THE SENATE COMMITTEE ON FINANCE CHAIRMAN S STAFF DISCUSSION DRAFT OF PROVISIONS TO REFORM INTERNATIONAL BUSINESS TAXATION Prepared by the Staff of the JOINT COMMITTEE ON TAXATION
More informationInternational Tax Thailand Highlights 2018
International Tax Thailand Highlights 2018 Investment basics: Currency Thai Baht (THB) Foreign exchange control Repatriation payments may not be made in THB, but may be made in any other currency. An exception
More informationInternational Tax Germany Highlights 2018
International Tax Germany Highlights 2018 Investment basics: Currency Euro (EUR) Foreign exchange control No restrictions are imposed on the import or export of capital; however, a declaration must be
More informationStudy on Structures of Aggressive Tax Planning and Indicators
Study on Structures of Aggressive Tax Planning and Indicators Platform for Tax Good Governance 15 March 2016 Gaëtan Nicodème Context Fair and efficient corporate tax system: priority of the Commission
More informationRecent developments in international tax
Recent developments in international tax Disclaimer EY refers to the global organization, and may refer to one or more, of the member firms of Ernst & Young Global Limited, each of which is a separate
More informationSubject Index. Canada: depreciation rules, ; generally accepted accounting principles, 202; inventory
Subject Index Accounting Standards Board, United Kingdom, 202 Accounting systems: country-specific practices, 202-8; differences in reporting, 183-93,201-2.221-23; German onebook, 185-88, 190; MNC tax-related
More informationTransformation in China: New Opportunities and Challenges
Transformation in China: New Opportunities and Challenges March 2008 The information contained herein does not constitute and shall not be construed to constitute investment, tax or legal advice by Deutsche
More informationSetting up your Business in Georgia Issues to consider
Georgia is one of the world s fastest growing economies and in the region is leading location for global investment. As a result of innovative reforms implemented in Georgia, the World Bank rated Georgia
More informationInternational Transfer Pricing
www.pwc.com/internationaltp International Transfer Pricing 2013/14 An easy to use reference guide covering a range of transfer pricing issues in nearly 80 territories worldwide. www.pwc.com/tptogo Transfer
More informationSummary of 2017 Tax Law Changes
1 2017 Tax Law: Massive Changes HR 1, as passed by Congress Stephen C. Fox, CPA 2 Overview Major corporate provisions, including rate cut to 21% Standard deduction up, exemptions gone Deduction for 20%
More informationTax Accounting Insights
No. 2018-03 16 January 2018 Tax Accounting Insights A closer look at accounting for the effects of the Tax Cuts and Jobs Act Revised 16 January 2018 ASC 740 requires the effects of changes in tax rates
More informationU.S. Tax Reform: The Current State of Play
U.S. Tax Reform: The Current State of Play Key Business Tax Reforms House Bill Senate Bill Final Bill (HR 1) Commentary Corporate Tax Rate Maximum rate reduced from 35% to 20% rate beginning in 2018. Same
More informationUS Corporate Taxation
Overview and Learning Objectives This course provides participants with an essential overview and comprehensive understanding of the complex US tax system, with particular emphasis on international aspects.
More informationInternational Tax New Zealand Highlights 2018
International Tax New Zealand Highlights 2018 Investment basics: Currency New Zealand Dollar (NZD) Foreign exchange control There are no restrictions on the import or export of capital. Accounting principles/financial
More informationInternational Tax Norway Highlights 2019
International Tax Updated January 2019 Investment basics: Currency Norwegian Krone (NOK) Foreign exchange control No Accounting principles/financial statements Norwegian GAAP and IFRS. Statutory accounts
More informationInternational Tax China Highlights 2017
International Tax China Highlights 2017 Investment basics: Currency Renminbi (RMB) or Yuan (CNY) Foreign exchange control The government maintains strict exchange controls, although the general trend has
More informationNew Swiss corporate tax developments : A paradigm shift?
New Swiss corporate tax developments : A paradigm shift? The Report of the Joint Steering Comittee (Federal Department of Finance and the Council of Cantonal Finance Ministers) Jean-Michel Clerc, Partner
More informationNew Tax Law: International
New Tax Law: International Provisions and Observations April 18, 2018 kpmg.com 1 In the context of international tax, the Public Law 115-97 (popularly, if not officially, referred to as the Tax Cuts and
More informationOECD issues Action Plan on Base Erosion and Profit Shifting (BEPS)
22 July 2013 OECD issues Action Plan on Base Erosion and Profit Shifting (BEPS) Executive summary On 19 July 2013, the Organisation for Economic Cooperation and Development (OECD) issued its much-anticipated
More informationTaxing Income Across International Borders. A Policy Framework
Taxing Income Across International Borders A Policy Framework 30 July 1991 PREFACE Minister of Finance, Hon Ruth Richardson Minister of Revenue, Hon Wyatt Creech TAXING INCOME ACROSS INTERNATIONAL BORDERS
More informationINTERNATIONAL TAX STRUCTURING FOR INVESTING ADROAD INTERNATIONAL TAX CONFERENCE
INTERNATIONAL TAX STRUCTURING FOR INVESTING ADROAD December 5, 2009 INTERNATIONAL TAX CONFERENCE - 2009 Shefali Goradia Partner, BMR Advisors OVERSEAS INVESTMENT KEY DRIVERS Access to Global Markets Inorganic
More informationTaxation of cross-border mergers and acquisitions
Taxation of cross-border mergers and acquisitions The Netherlands kpmg.com/tax KPMG International The Netherlands Introduction The Dutch tax environment for cross-border mergers and acquisitions (M&A)
More informationGeneral year-end tax planning for business
TaxTalk Insights General year-end tax planning for business 1 June 2015 With 30 June fast approaching, now is the time for companies with a 30 June tax year end to consider year-end tax planning strategies
More informationDouble Taxation Relief
Università Carlo Cattaneo LUIC International Tax Law a.a. 2017/2018 Double Taxation Relief Prof. Marco Cerrato 1 International Double Taxation Definition International juridical double taxation: «imposition
More informationKorean Tax Update BEPS Implementation
Presentation for KGCCI Korean Tax Update BEPS Implementation May 2018 CONTENTS I. BEPS: Backgrounds What is BEPS? Backgrounds for OECD BEPS Project BEPS Action plans II. BEPS Implementation in Korea I.
More informationDutch Tax Bill 2019: what will change?
1 Dutch Tax Bill 2019: what will change? On 18 September 2018, the Dutch government presented a number of tax measures as part of the 2019 budget proposals. The key measures are: Abolition of withholding
More informationReport on the United States of America
Arctic Circle This report provides helpful information on the current business environment in the United States of America. It is designed to assist companies in doing business and establishing effective
More informationInternational Income Taxation Chapter 1: INTRODUCTION
Presentation: International Income Taxation Chapter 1: INTRODUCTION Professors Wells January 20, 2016 Chapter One: Introduction Problem of Primary versus Secondary Taxing Jurisdiction: 1) Inbound investment
More informationAMERICAN JOBS CREATION ACT OF 2004
AMERICAN JOBS CREATION ACT OF 2004 OCTOBER 26, 2004 TABLE OF CONTENTS Page REPEAL OF EXCLUSION FOR EXTRATERRITORIAL INCOME AND DEDUCTIONS FOR DOMESTIC PRODUCTION ACTIVITIES... 1 TAX SHELTERS... 2 Information
More informationLaw 410/565 International Taxation Spring 2016
Law 410/565 International Taxation Spring 2016 Tuesdays & Thursdays 9:00 am 10:30 am Allard Hall, Room B101 PROFESSOR DAVID DUFF T: (604) 827-3586 E: duff@allard.ubc.ca Office: Allard Hall, Room 466 Office
More information