Category: International Tax Planning

27

Sep2017
The Israeli Tax Authority published final instructions regarding Reverse Vesting shares on June 5 (Circular 5.2017. This will be of interest to many people in the Start-Up Nation. Until now, founders and key personnel holding 10% or more of a company seemed to miss out on the opportunity ... Read More

19

Jul2017
The world’s tax treaties have just undergone instant plastic surgery. Unfortunately, they aren’t as pretty as they used to be. One of the surgeons in attendance was the Israeli finance minister, Moshe Kahlon. It all happened on June 7 in Paris, when the OECD held a grand ... Read More

08

Jun2017
Once upon a time in Never Land, a high tax country, Old Macdonald Inc. (OMI) hit upon a way of converting carrots into 24 carat pure gold at minimal cost. Unable to believe its good fortune, OMI licenses this knowhow to its subsidiary company OMI Offshore Ltd in ... Read More

22

Mar2017

22

Mar2017

23

Jan2017
At his inaugural speech on January 20, President Trump espoused two economic principles: "Buy American and Hire American". What else can the rest of the world expect? Immediately after the inauguration, the White House website provided a few more insights (https://www.whitehouse.gov/america-first-foreign-policy) "The world must know that ... Read More

27

Dec2016
Wouldn't it be nice if you could complain about tax authority bureaucracy. Now you can, if the complaints relate to failed attempts to apply tax treaty dispute resolution procedures. But hurry, there isn't much time to file the complaint. The Background – BEPS: On October 5, ... Read More

26

Dec2016

Your Taxes: Apple Sauce

December 26, 2016
The European Commission announced on August 30, 2016 that that Ireland granted undue tax benefits of up to €13 billion to Apple (http://europa.eu/rapid/press-release_IP-16-2923_en.htm).  The Commission said this is illegal under EU state aid rules, because it allowed Apple to pay substantially less tax than other businesses. ... Read More

26

Dec2016
The OECD has issued revised draft guidance on profit splits within multinational groups for transfer pricing purposes (BEPS Actions 8-10, Revised Guidance on Profit Splits July 4 – September 5, 2016). Israel joined the OECD in 2010. Why is this important? We live in ... Read More

26

Dec2016
Multinational groups, large and small, are now overhauling their international tax planning from top to bottom, due to BEPS, hopefully without getting into the Panama Papers. What is BEPS? On October 5, 2015 the OECD published a final comprehensive package of measures aimed at BEPS – ... Read More

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