June 17, 2015
On 16 April 2015, Advocate General Kokott („AG“) advised the CJEU to rule that the exclusion of foreign EU group members of an Austrian tax group from the goodwill amortization scheme is not in line with the freedom of establishment. The AG, furthermore, argued that the scheme does not constitute illegal State aid due to…
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June 10, 2015
Tax advisors in Israel are scrambling to find the best solution to the unknown risk of adverse tax treatment of reverse vesting. Why the current increased interest in the topic? Paranoia or calculated anticipation of the Israeli tax authorities (the “ITA”) attacking a well established principle? Reverse vesting is a commonly used technique to address…
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February 3, 2015
The breathless conundrum for IP companies is four-fold: not only should royalties be taxed at a low rate in order to maximise profits; but also research and development (R&D) or acquisition costs should be considered as allowable expenses to the maximum possible effect, whilst also the jurisdiction where the IP holding is situated should have…
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January 29, 2015
Foreigners who take up residence in Switzerland for the first time or after an absence of more than ten years may opt for a special tax regime provided that they will not carry out any gainful activity in the country. In doing so, they will benefit from the application of a special method for the…
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January 23, 2015
The UK encourages foreign direct investments by granting high net worth individual investors and their families the right to reside temporarily in its territory, with the associated tax benefits of the resident ‘non-dom’ regime. And after a qualifying period, whose length depends on the amount invested in the British economy, the individual and their kin…
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