Switzerland: Swiss Safe Harbour Interest Rates On Intra Group Loans For 2015

Interest rates on intra group loans are a recurring topic. The Swiss Federal Tax Administration (FTA) publishes safe harbour interest rates on an annual basis in advance. Their application will usually prevent unwelcome surprises. But there is more to it.

Annual guidance published by the FTA In its annually published advance guidance on intra group interest rates the FTA differentiates whether the Swiss company acts as creditor or debtor, what currency the loan was granted […]

By |April 13th, 2015|

UK: Tax Issues Update – April 2015 – IP Profit And Protection: Techniques For Future Success

Historically taxpayers have faced difficulty overcoming a presumption against a change in domicile to a foreign jurisdiction.

Intellectual property generally will be the most valuable asset held by technology companies and, in fact, many other business entities across all sectors of the economy. A recent analysis of S&P 500 companies showed that IP accounted for an average of over 80% of company value a considerable increase from only 17% 40 years ago. Whether the IP […]

By |April 13th, 2015|

India: Budget 2015: Amendment To Rule 6 Of CCR

The Budget 2015 has, quite notoriously, placed an amendment to Rule 6 of the Cenvat Credit Rules, 2004 by including non-excisable goods into its fold.

Vide Notification No. 6/2015, dated 1st March, 2015, two explanations have been added to Rule 6(1), after the proviso to these rules:

“Explanation 1. – For the purposes of this rule, exempted goods or final products as defined in clauses (d) and (h) of rule 2 shall include non-excisable goods cleared […]

By |April 10th, 2015|