Tax & Legal News – Issue 4, August 2015

In this issue: PwC Reports, Official Pronouncements, Supreme Tax Court Cases, From Europe and From PwC.

PwC Reports

  • Real estate transfer tax on share transfers unconstitutional
  • Automatic exchange of bank account information

Official Pronouncements

  • Progress payments lead to profit realisation
  • Draft FATCA regulations
  • Income documentation exemption for non-transparent investment funds only applies to EEA funds
  • Building installation continues to be VAT-able as building
  • Builders to treat customer retentions as bad debts

Supreme Tax Court Cases

  • Imputation credit for foreign corporation tax refused
  • Film pre-release marketing subsidy as profit-sharing loan
  • Subordinated debt not a liability whilst debtor’s liabilities exceed assets
  • Embezzled funds not taxable income
  • Pre-2008 disallowance of related-party loan interest
  • Regular remuneration can qualify for multi-year preference

From Europe

  • Non-residents need not be granted resident’s privileges in the year they take up employment elsewhere
  • Non-deductible loss on investment can include exchange loss
  • VAT group exclusion by legal entity only to prevent abuse
  • Nuclear fuel duty upheld
  • 5% non-deductible deemed expense for foreign dividends can infringe freedom of establishment?

From PwC

  • Breaking news


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