Switzerland: Landmark Judgments Regarding The Refund Of Swiss Withholding Tax

INTRODUCTION

On May 5, 2015 the Swiss Federal Supreme Court held a public hearing about two cases relating to the reclaim of Swiss withholding tax (WHT) in connection with arbitrage cases and issued its long awaited decisions. Two Danish banks issued the question on treaty entitlement for the refund of WHT based on the Swiss-Danish double tax treaty (DTT-DK) in connection with total return swaps and futures products.

The judgments have been decided to the disadvantage […]

By |May 19th, 2015|

Russian Federation: Russia’s Deoffshorisation: First Foreign Ownership Filing Deadline Approaching Swiftly

Ahead of their joint event on Deoffshorisation Compliance on 21 May, TMF Group’s Sub Regional Director for CIS and the Nordics Alex Medlock and Artem Toropov, Senior International Tax Associate at law firm Goltsblat BLP LLP (the Russian practice of Berwin Leighton Paisner), outline the key deoffshorisation/CFC compliance requirements and explain how Russian residents and companies will be affected.

Individuals and companies classified as Russian tax residents are facing the tight reporting deadline of 15 […]

By |May 19th, 2015|

Russian Federation: Tax Due Diligence And Self-Checks Of Tax Liabilities

A company’s tax risks and assets are generally evaluated in two situations:

During transactions to acquire a new business/assets; in this case, the buyer checks the tax risks of the target company (or companies) by ordering an expert overview, a so-called tax due diligence review;
In order to get an independent opinion on the existence of tax risks in one’s own company, generally such audits (they’re also called self-checks) are done by order of the company’s […]

By |May 19th, 2015|