June 6, 2011
Noteworthy International Tax Developments
- The 2011 United Kingdom budget, announced on March 23, 2011, reduced the maximum corporate tax rate to 26% (as of April 1, 2011), with additional rate reductions of 1% per year over the next 3 years, and also introduced a patent box regime providing for a 10% tax rate on income generated from patents commercialized after November 2010.
- The Chinese State Administration of Taxation recently issued a notice clarifying (and providing additional guidance with respect to) the rules regarding the reporting of indirect equity transfers in a Chinese company by a non-resident enterprise under Circular 698.
- The Brazilian Federal Revenue Department has issued a new regulation removing Luxembourg holding companies from its gray list of privileged tax regimes which are subject to more burdensome transfer pricing documentation requirements and stricter thin capitalization rules.
- On April 18, 2011, the Tax Information Exchange Agreement between the U.S. and Panama signed in December 2010 became effective, thereby allowing each country to request tax information from the other (in both civil and criminal matters) with respect to tax years beginning after November 30, 2007.
