Newsletter | April 2015

Dear Readers,


Spring has well and truly sprung in London – the blossom is out in force heralding the change of seasons and much welcomed warmer weather. Change is very much on the agenda, with Parliament dissolved and the UK General Election just weeks away, the coming months will be fascinating for those dealing with UK headquartered business structures. The major political parties have the economy as a key priority within their manifestoes and all make reference to the continuing commitment toward greater anti-avoidance measures. We look forward to updating you in detail on the post-election structuring landscape in our May newsletter.


To ensure you are kept up to date with post-election activity and any practical implications, don’t miss Phillip Baker QC’s session on ‘The Post-UK-Election Landscape for SMEs with Global Interests', at our one-day workshop on June 4 in London. Further information and registration details for the workshop can be found below, or by visiting the IBSA website.

Luxembourg

Join us in Luxembourg on 12 May for a discussion group examining 'Private Equity Funds'

Best wishes,

The IBSA Team

In global news, at the beginning of April the OECD released its latest discussion draft on BEPS Action 3, Strengthening CFC Rules. The discussion draft breaks down CFC rules into the seven ‘building blocks’ believed crucial to create a set of effective rules. The blocks comprise: Definition of a CFC; Threshold requirements; Definition of control; Definition of CFC income; Rules for computing income; Rules for attributing income; and Rules to prevent or eliminate double taxation. Comments should be submitted to the OECD by email by 1 May and addressed to Achim Pross, Head, International Co-operation and Tax Administration Division, OECD/CTPA. The usual public consultation is scheduled for the afternoon of 12 May and will be broadcast live online.

  

 

Speaking of 12 May, the IBSA will be in Luxembourg for our next European Branch meeting on that date. The topic on the agenda is ‘Private Equity Funds: practical financing techniques, fund management incentives and regulatory issues'. The discussion will examine fund structures, fund management entities and the impact of financing new and existing entrepreneurial ventures through private equity and venture capital funds. Register now to secure your place.

  


As always, we are keen to hear from our members so please do let us know of any comments or feedback in relation to the IBSA. Don’t forget to submit your articles for the next newsletter – deadline for submissions is 22 May.

 

 


UK Branch Event Summary

The April UK Branch Meeting saw a lively discussion around business incentive reliefs for entrepreneurs, with both the panellists - Jon Wingent, Paul Hocking, and Robert Field - and the audience highlighting views on the proposed abolition of the resident non-dom regime by Labour; the consequences and likelihood of a Greek exit from the EU and the increasingly complex tax code for real estate which combines ATED with the new capital gains tax charge on non-residents owning and disposing of UK properties. Read more >>

Upcoming Events

IBSA events are a great opportunity to find out more about us and meet some fantastic professional colleagues. Please note that IBSA members are entitled to attend Branch meetings anywhere in the world and receive a discount on all paid-for events.

Webinar

Resident Non-Domiciliaries & Overseas Investors to the UK


Dmitry Zapol (IFS) and Naomi Lawton (Memery Crystal) will provide a 45 minute webinar on resident non-domiciles & overseas investors to the UK.


In their presentation Dmitry & Naomi will address the following practical matters:


-Becoming UK resident at the appropriate time and avoiding common mistakes.

-Creating clean capital and investing it without unexpected UK tax liability.

-Tax-efficient investments in UK assets, including UK income tax, capital gains tax and inheritance tax.

-Using UK holding companies.

Webinar date & time:

28 April 2015


12:15 GMT

Hosted on:
European Branch Meeting - Luxembourg

Private Equity Funds: Practical financing techniques, fund management incentives & regulatory issues


Join us for a discussion group, kindly hosted by Vistra, examining fund structures, fund management entities and the impact of financing new and existing entrepreneurial ventures through private equity and venture capital funds.


Panellists including Wim Ritz, Julien Dif and Frédéric Dupont will examine a new and exciting secondary market providing liquidity strategies and portfolio management. Regulatory issues including AIFMD, key personnel employment incentives and international tax structuring issues will also be considered.

Date:
12 May 2015

Venue:

IBSA Workshop - London

Developing Strategies for International Business:

Examining a typical international group structure for problems and opportunities

 

You are invited to attend this one-day workshop, at which delegates will develop strategies for multinational businesses. A practical and interactive day, delegates will work through a case study of a typical entrepreneur's international group structure to understand how to plan and approach issues such as: transfer pricing, treaty access limitations, and tax incentives.

 

In the wake of the UK General Election in May, Philip Baker QC of Field Court Tax Chambers will discuss post-election issue affecting international business structures for UK SMEs with global interests.

 

Workshop delegates will have the valuable opportunity to learn from an international audience of their peers.

Workshop date:
4 June 2015
Venue:
Other info:

Exclusive Member Benefits

IBSA Connects

Connecting Members around the world.

To use this service simply email
IBSAConnects
outlining the jurisdiction, professions and specialty that you are looking for and the IBSA will put you in touch with Members that best fit your requirements.

Ask the IBSA

Need help locating country specific information? Missed the latest OECD announcements? Ask the IBSA and we will help locate it. Email Ask the IBSA with your query.


Please note this service does not provide technical advice - always seek the advice of your professional adviser.

Latest Articles

To read the full text of an article please click on the article title. If you are an IBSA Member and wish to submit an article for inlcusion in the Knowledge Bank please contact Jay Abai detailing the proposed topic. 

NORWAY - TRANSFER PRICING: CONFIDENTIALITY OK, TRANSPARENCY VIOLATED

Keith Brockman, Mars LTD

A recent KPMG Alert highlights a dangerous precedent for transfer pricing audits in Norway. In summary, the Supreme Court has ruled that Norwegian tax authorities may use comparables of other taxpayers to provide assessment information for a taxpayer, while asserting that such information is confidential.

CYPRUS - THE NEW INVESTMENT FUND CENTRE IN EUROPE
Andreas Athinodorou, Aspen Trust Group

The enactment of the new Alternative Investment Funds Law and the UCITS IV Directive are the latest in a long line of efforts in transforming Cyprus into a true financial jurisdiction.

BEPS ACTIONS 3 AND 12: PLUS AUSTRALIA'S DIVERTED PROFIT TAX

Keith Brockman, Mars LTD

EY’s Global Tax Alert of 13 April 2015 sets forth the latest summary of OECD BEPS developments, including the recent discussion drafts under BEPS Actions 3 and 12.

3RD SWISS CORPORATE INCOME TAX REFORM UPDATE

Aliasghar Kanani & Thierry Boitelle, Bonnard Lawson


Swiss federal council set the parameters on 2 April 2014. In order to render its corporate tax system compatible with new international and European standards, Switzerland proposes the 3rd Corporate Income Tax Reform, which should reinforce the Swiss tax system, further its international acceptance and strengthen the competitiveness of Switzerland as a preferred multinational business location.

AMENDMENT OF SPANISH LAW 29/1987, OF 18 DECEMBER, ON INHERITANCE AND GIFT TAX
Alix Sáenz de Cenzano Fargues & Cristina Ferrer-Sama, Azcona Asociados

On 28 November 2014, law 26/2014, of 27 November was published in the Official State Gazette. This law amends the law 35/2006, of 28 November of the Personal Income Tax Law, the restated text of the Spanish Non-resident Personal Income Tax Law, approved by Royal Legislative Decree 5/2004, of 5 March, and other tax regulations. Specifically the third final provision of said law amends Law 29/1987, of 18 December, on the Inheritance and Gift Tax, adjusting it to tax legislation as established in the Judgment issued by the Court of Justice of the European Union on 3 September 2014.

Website

Phone: +44 (0) 20 7030 3310

Email: jay.abai@istructuring.com