Emma Powell

Germany proposes to limit participation exemptions for hybrid instruments

The German government has once again proposed to limit participation exemption to dividends that have not been deducted at the distributing entity level. The measure may force taxpayers to reassess the pricing of hybrid instruments.

Emma Powell, March 07, 2013

Korea clarifies arm’s-length calculation of intercompany guarantee transactions

The Korean government has issued guidance on the calculation of the arm’s-length price of guarantee fees for intercompany-guarantee transactions in response to a growing number of disputes involving companies receiving guarantee fees from their foreign subsidiaries.

Emma Powell, March 05, 2013

South Africa limits interest deductibility on related party debt

New limits will be placed on the deductibility of interest on related party debt under the South African budget 2013, announced yesterday. However taxpayers are yet to receive clarification on the application of the arms-length test for inbound financial assistance.

Emma Powell, February 28, 2013

HMRC is exchanging unilateral APA information with treaty partners

HMRC is exchanging the terms of its unilateral advance pricing agreements (APA) with UK tax treaty partners. The measure is part of the revenue’s drive towards greater transparency and began this month.

Emma Powell, February 26, 2013

France reassesses cooperative list of tax treaty states

The French government will reassess how effectively information is exchanged with bilateral treaty partners to reduce the loss of revenue through cross border transactions.

Emma Powell, February 21, 2013

Taxpayers need cost-sharing law in Russia to combat shared service disputes

Taxpayers need cost-sharing provisions to be written into Russian tax legislation to combat an increased risk of dispute over the allocation of shared service costs.

Emma Powell, February 19, 2013

Emma Powell

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