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Eversheds Sutherland (International) LLP | Germany | 16 Aug 2022

Der "Tax One Pager": Änderung des Steuerabzugs nach § 50a EStG bei Softwareauftragsentwicklung

Seit der Änderung des UrhG im Juni 2021 besteht aus steuerlicher Sicht die Möglichkeit, das wirtschaftliche Eigentum an Urheberrechten an Software zu…
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Hogan Lovells | United Kingdom | 15 Aug 2022

Potential additional hurdle to clear if interest on intra-group debt is to be tax deductible in the UK

In applying the UK’s transfer pricing rules, tax advisers have to think beyond the amount of the debt and the interest rate to get comfortable that an…
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SS Rana & Co | India | 11 Jul 2022

TDS Deduction Norms for Virtual Digital Assets Out- India

In March 2020 the Supreme Court in re Internet and Mobile Association of India v. Reserve Bank of India overturned the RBI circular banning the trade…
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CETINKAYA | Turkey | 4 Jul 2022

Istanbul Finance Center Law Entered Into Force

In the Official Gazette dated June 28, 2022, and numbered 31880, the Istanbul Financial Center Law Numbered 7412 (the “Law”) was published by the…
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KPMG Law | Canada | 4 Mar 2022

Draft tax legislation: limitations on deductible interest expense and other measures

Taxpayers may want to review proposed changes to the interest expensing rules and other significant new draft tax legislation that was recently issued by the Department of Finance. This new extensive package of legislation features a wide range of corporate, personal and trust tax changes. This article looks at the proposed limitations on deductible interest expense and other measures.
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Pinsent Masons | United Kingdom | 25 Feb 2022

UK hybrid and other mismatches rules: some welcome changes

UK hybrid and other mismatches rules broadly apply in cross-border transactions. However, the regime can also apply to purely domestic transactions. In essence, for the rules to apply, hybridity will be a structural mismatch either in the way a payment is treated, or in the different ways that countries might treat an entity. Where the rules apply, they can deny a UK tax deduction for......
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Studio Legale e Tributario Biscozzi Nobili Piazza | Italy | 14 Jan 2022

Changes to Patent Box regime

With Law Decree 146/2021, the Italian government replaced the former "Patent Box" regime. The new provisions modify the nature of the existing regime. There will no longer be a profit-based benefit; rather, it will translate into an additional 90% cost deduction for research and development costs incurred by Italian taxpayers relating to copyrighted software, patents, trademarks, designs,......
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Colin Biggers & Paisley Lawyers | Australia | 2 Dec 2021

Tax deductibility of payments to cancel entitlements under employee incentive schemes

In Clough Limited v Commissioner of Taxation [2021] FCAFC 197, the Full Federal Court finds that payments to employees to cancel their entitlements…
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Cornwalls | Australia | 18 Aug 2021

Interest expenses not always deductible

In a decision that may send chills down the spine of Australian corporate groups, the Full Federal Court recently denied a tax deduction for interest…
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Studio Legale e Tributario Biscozzi Nobili Piazza | Italy | 16 Jul 2021

ACE rate will increase to 15%

Decree-Law 73/2021 has introduced a one-off enhancement to the Aid to Economic Growth (ACE) benefit for the fiscal year starting after 31 December 2020. Under the ACE regime, Italian-resident companies and permanent establishments of non-resident companies may deduct notional interest from their corporate income taxable base for the relevant fiscal year.
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