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Taxand's Take - Your regular update on the latest issues affecting multinationals
Welcome to the latest edition of Taxand's Take - your regular update on the topical tax issues affecting multinationals. Accessible online this newsletter is sent to you every two months. And Taxand's Take will give you just that - informed opinion on the latest tax changes and how they affect you.
Cyprus / Russia - Amendments to the Cyprus-Russia Double Tax Treaty (DTT)
7 October 2010 saw the signing of a Protocol on Amendments to the 1998 Double Taxation Treaty (DTT) between the Russian Federation and the Republic of Cyprus. The new Protocol has received much publicity in recent months and this is not surprising since it promises to bring about changes in the current taxation regime between the two countries. Although the 1998 DTT created a reciprocal trading and investment relationship between the two Countries, Cyprus was included in 2008 in the Russian Tax Authorities "List of Offshore States" amongst 42 countries. The Russian black list essentially barred Cypriot subsidiaries of Russian Companies to obtain a tax exemption on their dividends. Taxand Cyprus and Taxand Russia review the amendments to the Cyprus-Russia DTT and its benefits for investors. In particular one of the most important and widely discussed amendments was the new Article 26 on exchange of information.
Spain - Tax Measures to Attract Investment in Spain
December saw the publication of new measures on tax, employment and deregulation measures to promote investment and the creation of employment, which approves some important measures. Taxand Spain highlights the latest tax modifications being enforced within Spain and how this benefits foreign investors.
Canada / Switzerland - Canada-Switzerland: Amendment to Double Tax Treaty to Meet OECD's Standard on Information Exchange
On 22 October 2010 the Government of Canada and Swiss Federal Council signed a protocol ("Protocol") to amend the 1997 Convention between Canada and Switzerland for the Avoidance of Double Taxation with Respect to Taxes on Income and on Capital ("Convention"). Taxand Canada and Taxand Switzerland highlight the significant amendments made in the protocol to the convention.
US - 2010 Tax Relief Act -- An Early Holiday Gift for US Taxpayers
On 17 December 2010, President Obama signed into law the controversial and much anticipated Tax Relief, Unemployment Insurance Reauthorisation, and Job Creation Act of 2010 (commonly referred to as the "2010 Tax Relief Act" or the "Act"). The Act prevents the sunset of many important and beneficial tax provisions (referred to as the "Bush-Era Tax Cuts") for US taxpayers. The Act also includes some important tax incentives intended to spur economic growth. US taxpayers, and especially businesses and "high-income" taxpayers, should rejoice from this early holiday gift. Taxand US examines the new act, its incentives and why this is a welcome relief for taxpayers and how they can all benefit.
China - China Tightens the Regulations of the Representative Offices of Foreign Enterprise
The State Council released the Regulations on the Administration of Registration of Resident Representative Offices of Foreign Enterprises (the "Regulations") on 19 November 2010 to tighten the regulation of the Representative Office ("RO") registrations effective from 1 March 2011. This is aimed to replace the prevailing Measures for the Administration of Registration of Resident Representative Offices of Foreign Enterprises that were approved by the State Council on 5 March 1983. Taxand China analyses the regulations provided in the detailed regulation measures.
Poland - Polish CIT Act to Fully Exempt EU and EEA Funds
Under the Polish domestic rules, Polish investment funds are subject to a special Corporate Income Tax (CIT) regime. Namely, the CIT Law provides for a full exemption from income tax for "investment funds operating pursuant to provisions of the Polish Act on Investment Funds". As a consequence, the funds covered by the Polish domestic regulations are subject to, but fully exempt from income tax in Poland. Taxand Poland highlights the benefits of the CIT regime and the change in exemptions.
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Taxand firms have produced this tax newsletter in connection with the marketing of our tax services relating to matters discussed therein. Each taxpayer should seek advice based on the taxpayer's particular circumstances from an independent tax advisor. Taxand is a global organisation of tax advisory firms. Each firm in each country is a separate and independent legal entity responsible for delivering client services.
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