Ireland: Matheson Tax update: Finance (No. 2) Bill 2013

The Irish Government published the Finance (No.2) Bill 2013 (the “Bill”) on October 24, 2013. The Bill contains a number of measures which will be of interest to international companies.
Corporate Residence Rules
The Bill proposes measures to curb the existence of so-called “stateless” companies. The proposed legislation is along expected lines and has a narrow application to deal with mismatches which can arise as a result of the different tests for residence which exist in […]

By |October 8th, 2013|

China: Managing Offshore Holding Companies From China: Recent Case May Suggest Increased Tax Risk

As our readers know, foreign investments into the People’s Republic of China (“PRC”) are typically structured through one or more holding companies domiciled in offshore jurisdictions. Planned and implemented properly, an offshore holding company structure can provide investors with enhanced governance and economic rights, ease of public listing and disposal without triggering onshore regulatory approvals, and reduced withholding tax rates on returns of their PRC investments compared to a direct investment into a PRC […]

By |October 8th, 2013|

United Kingdom: Weekly Tax Update – Monday 28 October 2013

1 General news
1.1 First-tier Tribunal awards costs in case where HMRC had no reasonable prospects of success
A case recently heard in the First-tier Tribunal has once again raised the question whether HMRC operates a suitably robust filter system to ensure that cases taken to Tribunal have merit.

On 13 September 2012 the Tribunal upheld an appeal by ND and RC Roden against a review decision issued by HMRC refusing to repay £70,000 in input VAT.

HMRC’s […]

By |October 7th, 2013|