Fall 2017

The fall edition of the International Tax for Asset Managers Update highlights recent tax developments and breaking news from the United Kingdom (UK) focused on investment managers. This edition includes representative updates on the following:

• Brexit: Tax considerations for UK asset managers operating in the EU
• Diverted Profits Tax: An extra-territorial tax on profits diverted from the UK
• UK tax governance framework for US managers
• Anti-avoidance: Impact of the new disguised investment management fee rules on US managers with UK operations
• Transfer pricing for investment management businesses
• Legislation introduced to counteract hybrid mismatches is potentially very wide reaching in application

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Summer 2016

The summer edition of the International Tax for Asset Managers update, a quarterly summary of recent tax developments from around the world, focuses on investment management tax professionals. The latest issue includes the following representative updates:

• India: CBDT issues press release towards protocol for amendment of the Double Taxation Avoidance Agreement between India and Mauritius
• Chile: New regulation opens opportunities for foreign investors
• United States: IRS Issues Notice 2016-42
• France: Panama re-added to list of noncooperative jurisdictions
• Australia: Australia’s tax authorities target cross-border profit-shifting arrangements
• Luxembourg: The Reserved Alternative Investment Fund

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Winter 2016

The winter edition of the International Tax for Asset Managers update, a quarterly summary of recent tax developments from around the world, focuses on investment management tax professionals. The latest issue includes the following representative updates:

• United States: President signs extenders package
• Belgium: Excess profit rulings constitute illegal state aid
• Germany: New treaty with Netherlands revises tax treatment of gains on real estate company shares
• India: AAR rules that proposed transfer of shares not for tax avoidance, confirms nontaxability of capital gains under India-Mauritius treaty
• China/Hong Kong: Mainland Chinese tax treatment of investors in Mainland-Hong Kong mutually recognized publicly offered funds clarified
• Australia: ATO publishes “client experience roadmap” for MAAL

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Fall 2015

The fall edition of the International Tax for Asset Managers update, a quarterly summary of recent tax developments from around the world, focuses on investment management tax professionals. The latest issue includes the following representative updates:

• United States: OECD releases final BEPS reports
• United States: Final and temporary rules issued on treatment of dividend equivalents under section 871(m)
• Peru: Temporary tax exemption to apply to certain share sales
• Netherlands: Supreme Court rules SICAV not entitled to refund of dividend withholding tax
• India: Government issues clarification on minimum alternate tax
• Australia: Investment Manager Regime law enacted

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Summer 2015

The summer edition of the International Tax for Asset Managers update, a quarterly summary of recent tax developments from around the world, focuses on investment management tax professionals. The latest issue includes the following representative updates:

• United States: Proposed regulations address the PFIC status of foreign insurance companies
• United States: OECD releases revised discussion draft on BEPS Action 7— Preventing artificial avoidance of PE status
• United States: OECD: Discussion draft on cost contribution arrangements released
• Peru: Nonresidents must obtain certification of tax basis for indirect transfers of shares
• Switzerland: Swiss Supreme Court rules on treaty beneficial ownership in connection with derivative transactions
• India: In a major relief to FIIs, MAT proceedings put on hold by the government
• Australia: Investment manager regime bill introduced into parliament

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Spring 2015

The spring edition of the International Tax for Asset Managers update, a quarterly summary of recent tax developments from around the world, focuses on investment management tax professionals. The latest issue includes the following representative updates:

• United States: United States presidential budget proposal for FY 2016 released
• United States: OECD tax alert: Discussion draft released on deductibility of interest expense
• Spain: Requirements to benefit from WHT exemption for dividend distributions to EU parent companies relaxed
• Luxembourg: Guidance on commercial activities
• Luxembourg: Luxembourg revises tax ruling practice
• China: MOFCOM unveils draft of new foreign investment law
• China: SAT issues new rules on indirect transfers of assets by nonresident enterprises
• Japan: 2015 tax reform proposals announced

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Fall 2014

The fall edition of the International Tax for Asset Managers update, a quarterly summary of recent tax developments from around the world, focuses on investment management tax professionals. The latest issue includes the following representative updates:

• United States: OECD releases the BEPS project 2014 deliverables
• United States: PFIC reporting relief for mark-to-market investments
• United States: Treasury anti-inversion notice
• France: New protocol to treaty with Luxembourg addresses taxation of gains on shares in real estate companies
• Germany: Upper house of parliament proposes new anti-hybrid rule and other measures
• Finland: Changes proposed to tax treatment of dividends received by foreign pension institutions
• India: Delhi High Court clarifies tax consequences of indirect share transfers
• China: Official guidance on tax treatment for MMA/QFII/RQFII

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Summer 2014

The summer edition of the International Tax for Asset Managers update, a quarterly summary of recent tax developments from around the world, focuses on investment management tax professionals. The latest issue includes the following representative updates:

• United States: Stop Corporate Earnings Stripping Act of 2014
• Mexico: Recent tax rules issued by Mexican tax authorities
• Brazil: Switzerland moved from black list to gray list status
• Malta: Treatment of investment committee fees derived by nonresidents clarified
• Egypt: Amended tax laws
• India:
  • Budget highlights: A change in direction
  • Budget 2014: Impact on foreign portfolio investors
• Russia: Releases draft law that would introduce concept of “beneficial owner”

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Spring 2014

The spring edition of the International Tax for Asset Managers update, a quarterly summary of recent tax developments from around the world, focuses on investment management tax professionals. The latest issue includes the following representative updates:

• United States: Administration proposes six new international tax revenue raisers in its FY2015 budget
• United States: Temporary PFIC regulations
• Canada: Inbound financing and anti-treaty shipping measures
• European Union: The DFA case decision released, positively impacting U.S. and other non-EU investment funds
• Portugal: Changes to the debt securities regime
• United Kingdom: 2014 budget announced
• Germany: Substantial changes to the investment taxation system
• China: SAT issued Bulletin concerning determination of the "beneficial owners" under "entrusted investment" structures

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​Winter 2014

The winter edition of the International Tax for Asset Managers update, a quarterly round-up of recent tax developments from around the world, continues to focus on investment management-specific issues affecting global tax professionals. The latest issue includes the following representative updates:

• United States: Baucus international tax reform proposals
• United States: Final and newly proposed dividend equivalent regulations issued under 871(m)
• Austria: Draft of 2014 tax reform bill
• Hong Kong: Tax audit into offshore funds
• India: Cyprus designated a noncooperative jurisdiction
• India: FPIs to get similar tax treatment as available to FIIs
• India: SEBI (foreign portfolio investors) regulations 2014
• Australia: New draft legislation released on investment manager regime

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