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ABOUT THE AUTHOR
FORMS OF DOING BUSINESS
Main Forms of Doing Business with a Legal Presence
Main Forms of Doing Business
Specific Uses of Available Legal Entities
Specific Constraints of Available Legal Entities
Types of Partnerships and Hybrid Entities Available for International Business / Structuring
FORMATION
Main Formation Requirements
Tax Consequence of Contributions
CORPORATE RESIDENCE
Corporate Tax Residence
Practical Aspects of Tax Residence
Potential Exclusion from Treaty Benefits for Failure to Meet Residence Test
Potential Loss of Tax Residence Status by Domestic Entities
Potential Acquisition of Tax Residence Status by Foreign Entities
Deemed Acquisition of Tax Residence Status by Foreign Entities
Tax Consequences of Acquisition or Loss of Tax Residence
Specific (Deemed) Residence Rules for Partnerships, Hybrid and Specific Other Entities
PERMANENT ESTABLISHMENTS
Foreign PE of a Domestic Entity
Domestic PE of a Foreign Entity
PE Force of Attraction Principle
Branch Profit (Deemed) Remittance Tax
PE Risk Grid for Foreign Entities Involved in Business Activities
TAX BASE
Tax Base for Resident Entities
Treatment of Foreign Profits / Losses
Tax Consolidation / Group Treatment
Tax Base for Non-Resident Entities
Source Rules with Respect to Income Derived by Non-Residents
Qualification of Specific Income Categories for Tax Purposes
DETERMINATION OF TAXABLE INCOME
Main Rules Governing the Determination of Taxable Income
Main Differences between Commercial and Tax Accounting
Depreciation and Amortization
General Rules
Depreciable and Non-Depreciable Assets
Person Entitled to Claim Depreciation
Intangible Assets
Goodwill
Other Assets
Depreciation
Reserves and Provisions
Deduction of Cross-Border Payments and Non-Deductible Expenses
Main Rules for Deductions
Interest
Dividends
Royalties
Special Remunerations (E.g. Bonuses and Directors’ Fees)
Service and Management Fees
Research and Development
Direct and Indirect Taxes and Similar Levies
Expenses Paid Abroad
Other Deductions
Non-Deductible Expenses
Excluded and Segregated Income
Exempt Income and Receipts not Considered Income for Tax Purposes
Inter-Corporate Transfers
LOSSES
TAX RATES
Residents
Other Taxes
Non-Residents
Corporate/Profit Taxes
Withholding Taxes
Exit Strategies
FOREIGN TAX CREDITS
Unilateral Relief
Treaty-Based Relief
INCENTIVES AND SPECIAL REGIMES
Holding Regimes
Financing Regimes
Intellectual Property Management Regimes
Specific Regimes
Other Regimes
Other Incentives
BUSINESS TRANSFORMATION AND RE-ORGANIZATION
Direct and Indirect Tax Consequences of Re-Organizations
Tax Consequence of Business Emigration, Corporate Inversions and the Cessation of Business
VAT ON INTERNATIONAL TRANSACTIONS
VAT on the Supply of Goods by Non-Residents
VAT on the Supply of Services by Non-Residents
Refund of VAT to Non-Residents
BASE PROTECTION AND ANTI-AVOIDANCE MEASURES
GAAR and General Anti-Avoidance Measures
Thin-capitalization and other Restrictions to Interest Deduction
Thin-Capitalization Rules
Transfer Pricing
Main Rules
Specific TP Issues
Documentation Requirements
APAs and Dispute Resolution Mechanisms
Other Anti-Avoidance Rules
Anti-Tax Haven Rules
Controlled Foreign Company rules
TAX MANAGEMENT AND COMPLIANCE
Books and Records
Type of Assessment
Calendar of Important Compliance Events
Tax Audits
Interest and Penalties
Interest Compensation for Overpayment of Tax
Appeal Procedures
TAX CONTROVERSIES
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