Increase in globalization and foreign trade in the last century led to aggressive tax planning. Though these planning measures are legitimate, they are designed for shifting profits to low tax jurisdictions. There is a number of measured to deal with this tax abuse. In particular, some jurisdictions apply controlled foreign corporation (CFC) rules.
Historically, the CFC concepts were created to help prevent tax evasion achieved by setting up offshore companies in tax havens, such as Bermuda and the Cayman Islands. Increasingly countries have developed CFC legislation to counter perceived overseas abuses enveloped in a low tax overseas entity.
The aim of CFC rules is to prevent or obstruct the creation of structures used by companies, especially domestic multinationals, for pure avoidance of domestic tax liability. CFC rules are designed to prevent profit shifting without penalizing foreign subsidiaries engaged in legitimate business practices.
A controlled foreign corporation is a corporate entity that is registered and conducts business in a different jurisdiction or country than the residency of the controlling owners. A company that qualifies as a CFC generally has its...
The Government of Sweden has decided to review its policy on gaming by adopting a bill on the legal regulation of gaming, the entry into force of which is planned for January 1, 2019.
The bill was supported by over 90% of the present members of Swedish Parliament. The only political force that voted against was the Left Party (ex-Communists). Nevertheless, it did not affect the final result.
The result of the adoption of this bill was the transition of Sweden to a regulated market of gaming both online and offline. The new rules provide for changes in tax rates, increased requirements for operators and introduction of a licensing system in the country.
The history of the development of gaming business in Sweden is very interesting. The control over gaming has been carried out and is carried out by the only state company Svenska Spel. The state owns all the rights to open and regulate the gaming business, private companies in Sweden are forbidden to make gaming business. The company Svenska Spel regulates the market of lotteries, poker, bingo, as well as the market of land casinos, which belong to its subsidiary company Casino Cosmopol AB. Initially, it was planned to open six...
Many citizens who own residential and non-residential real estate intend to lease it. But they have some questions: is it necessary to register as an entrepreneur in this case, are there any peculiarities in taxation and are there any restrictions?
According to Art. 319, 320 of the Civil Code of Ukraine - the owner owns, uses, disposes of his property at his own discretion and has the right to make any actions with respect to his property that do not contradict the law, including using his property for entrepreneurial activities.
As we can see, the realization of the right to lease his own real estate by a natural person can be carried out both within the framework of entrepreneurial activity (by a natural person-entrepreneur) and outside of entrepreneurial activity (without registration by a natural person-entrepreneur).
We will consider in detail, what is the difference between a natural person and a natural person-entrepreneur, when leasing his own real estate.
The features of taxation of income of a natural person from leasing of real estate is regulated by art. 167, art. 170 of the Tax Code of Ukraine, Resolution of the Cabinet of Ministers of Ukraine No. 1253...
It’s not a secret for anyone that in order to protect your rights and protected interests, in the event of a tax dispute, taxpayers apply to the district administrative courts.
Since December 15, 2017, the procedure of appeal and the consideration procedure in the district administrative courts has changed significantly, in connection with the entry into force of the new edition of the Code of Administrative Court Procedure of Ukraine.
The number of novels that appeared in the new edition of the Code is quite significant. In this article, I would like to provide an overview of such an innovation in administrative procedure as the Single Judicial Information and Telecommunication System.
Article 18 of the Code of Administrative Court Procedure of Ukraine defines the tasks that are imposed on the Single Judicial Information and Telecommunication System (hereinafter - the System):
registration of documents entering the court (which may be the subject of litigation);
determination of the judge(s) for the consideration of the case;
exchange of documents (sending and receiving documents) in electronic form between the courts, between the court and the participants to the legal...