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Special Report on

Branches and thin capitalisation

branches and thin capitalisation special research report Photo by japantax.org
HM Revenue & Customs (HMRC) have released updated thin capitalisation guidance.  Since the last guidance was released significant changes have occurred in borrowing trends and the wider economic environment.  HMRC have taken the opportunity to establish their views on these issues. The guidance marks a change in the approach taken by HMRC with a shift in emphasis away from quantitative rules of thumb and definitive ratios (e.g. 1:1 debt to equity) to a more traditional detailed transfer pricing analysis based on the business plan, position within the industry sector, economic environment and rationale for debt ...
Relative to the size of its economy, Iceland’s banking collapse is the largest suffered by any country in economic history. In late September 2008, it was announced that the Glitnir bank would be nationalised. The following week, control of Landsbanki and Glitnir was handed over to receivers appointed by the Financial Supervisory Authority (FME). Soon after that, the same organisation placed Iceland's largest bank, Kaupthing , into receivership as well. Commenting on the need for emergency measures, Prime Minister Geir Haarde said on 6 October, "There [was] a very real danger ... that the Icelandic economy, in the ...
REVIEWS AND OPINIONS
From Asia Transfer Pricing Blog…
The China’s new Corporate Income Tax (“CIT”) Law has introduced the concept of thin capitalisation.  The deduction of interest expenses is not allowed when the ratio of debt to equity from related parties exceeds a certain prescribed debt/equity ratio as stipulated in Caishui [2008] no.121 (“Circular 121″).  For details of Circular 121 and our comments, please refer to the October 2008, Issue 10 of our News Flash . Most overseas banking groups operating in China are now aware of their obligation to apply transfer pricing principles to their related party transactions, to file the nine related party ... market research, surveys and trends
AVOID SKS Microfinance: Extremely Expensive and Hyped out of ...
SKS Microfinance Limited is tapping the capital markets and the issue which has opened on Wednesday the 28th of July closes on Monday for other applicants while it has closed for QIB’s on Friday. The company had made an anchor allocation as well and a total of 30,22,484 shares were allotted to 36 entities at the top end of the price band of Rs 850 to 985. This issue has been hyped and has been embroiled in controversies and could change the way people look at microfinance companies going forward. At the end of bidding for QIB’s a total of 14,37,20,703 shares were bid for making the remaining QIB portion ... market research, surveys and trends

SURVEY RESULTS FOR
BRANCHES AND THIN CAPITALISATION

Asia Pacific Tax Complexity Forecast: Where are your challenges?
Jun 8, 2010 ... 2010 GDP growth of 8.5 percent for India and 11 percent for China, it is now .... US$20 billion to less than US$500 million, include ...... The thin capitalisation threshold for non-resident .... The rate is 30% for domestic companies and 40% for foreign companies and branches of foreign companies. ... industry trends, business articles and survey research
A Practical Insight to Cross-Border Corporate Tax Work—Czech Republic
n Gift tax in the range of seven percent to 40 percent, levied on the value of property, reduced by related ... to-equity ratio and other conditions under thin capitalisation rules. In addition to interest, ... 1 million on loans and credits from unrelated parties. .... profits tax (or other tax limited to branches ... industry trends, business articles and survey research
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INFORMATION RESOURCES

Tax Alert Budget 2010
Branches and thin capitalisation. DISCLOSURE IS GOOD FOR THE SOUL - AMNESTY FOR. FULL DISCLOSURE. Taxpayers are to be afforded a voluntary disclosure period ... technology research, surveys study and trend statistics
199938031 [PFP#991178229]
Branch Chief CC:INTL:Br1. SUBJECT: The Classification of Endorsement Income Under U.S. .... 2, Thin Capitalisation, Taxation of Entertainers, ... technology research, surveys study and trend statistics
This approach is promising because WTO law otherwise presents an ...
power to tax, the tests for the justification of thin capitalization rules remain .... offsetting for foreign branches and even for foreign subsidiaries. ...
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BRANCHES AND THIN CAPITALISATION
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