Investment
Analysis
TAXATION
Tax is one of the single most decisive issues for companies or individuals seeking attractive locations for their assets. This section deals with the tax strategies of individual territories, the extent of compliance with international standards of transparency, the impact of tax planning on investors and the changes in tax policy on portfolions.
It also examines the changing environment for international and global tax planning and the attitude of revenue authorities worldwide to international financial centres. We also identify innovative tax planning approaches by centres and firms.
TAX INFORMATION EXCHANGE AGREEMENTS
In Spring 2009, there has been a burst of activity by multiple jurisdictions to sign tax information exchange agreements (TIEAs). Several of these agreements were signed in the week before the G20 met in London. This section analyses the phenomenon of the tax information exchange agreement and its status.
MAURITIUS
Mauritius and double tax treaties
Sonia Xavier, of Conyers Dill Pearman in Mauritius, looks at the impact of double tax agreements on Mauritius as an investment destination
SINGAPORE
Singapore issues guidance on related-party loans
The Inland Revenue Authority of Singapore (IRAS) issues new guidance on the transfer pricing issues around related-party loans. Deloitte in Singapore explains. The new IRAS supplementary circular states that the arm’s length principle should govern all related-party transactions, including loan arrangements between related parties.
IRELAND
The attraction of the Irish corporate tax regime
A hugely favourable corporate tax regime in Ireland has encouraged companies to relocate their headquarters to the jurisdiction. This article by IDA Ireland explains the thinking behind the Irish givernment's tax strategy and how it works in practice.
SWITZERLAND
Multinational insurance groups are now restructuring their operations in light of the changing legal framework in the EU and the subsequent implementation of Solvency II. Currently, the EU Life and non-Life insurance Directives, further supported by the introduction of the EU Reinsurance Directive allow direct insurers and pure reinsurers to enjoy passporting rights, where they may underwrite business in other EEA member countries whilst being subject to regulation by their Home State regulator for all business underwritten in the EEA. Mandatory implementation for all EEA member states was required in December 2007.
