The Spanish "REIT" was founded in October 2009 under the name of Sociedades Anónimas Cotizadas de Inversión en el Mercado Inmobiliario ("SOCIMI"). Its legal regime was set out in the Law 11/2009 of 26 October, which was subsequently amended by Law 16/2012 of 27 December to relax the legal requirements for their incorporation, remove the regulatory barriers and enhance the tax treatment applicable from 2009.
Tax incentives granted at the federal level bolster the Brazilian economy. Those incentives apply to the oil and gas industry, in particular. Learn more about the Special Customs Regime of Export and Import of Goods destined to Exploration and Production of Oil and Natural Gas (“REPETRO”), which is one of the main incentives applicable to this industry.
CRA narrowly interprets foreign affiliate income recharacterization rule. Read this short blurb to find out more.
In the recent decision of Nottawasaga Inn. Ltd. v. R. (2014 DTC 1021), the Tax Court of Canada (“TCC”) held that it had no jurisdiction to hear an appeal from a reassessmentof arrears interest where there exists a nil assessment of taxes and the sole basis for the appeal is not the calculation of the interest itself but the computation of the underlying taxable income on which the interest was calculated.
Last year, the Internal Revenue Service published Ordinance 1,793/2013, which lays out new criteria for monitoring high-value corporate taxpayers. The goal is to increase tax compliance and tax revenue. This article views which taxes are covered by the corporate tax monitoring programme.
A review of strategies to reduce social security contribution costs under Brazilian law.
A review of changes to Brazilian laws related to social security contributions. In some economic sectors, Brazilian law reduce social security contribution requirements to encourage growth.
A review of procedural tax law in Portugal, with a focus on the burden of proof in tax cases.
A review of tax offsetting under Brazilian law as well as recent developments in the relevant laws and regulations.
The following article is a discussion of a draft of tax regulations recently approved by Parliament.