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🌍 Navigating Tax Advisory in Norway: Key Insights for Businesses In today's globalized economy, effective tax advisory is more crucial than ever, especially in high-compliance environments like Norway. Businesses operating here face unique tax challenges that require strategic expertise to navigate efficiently and responsibly. 🔹 Why Tax Advisory Matters in Norway Norway’s tax framework is known for its robust compliance standards, with corporate tax rates, VAT obligations, and environmental levies that impact various sectors differently. For companies, from startups to multinationals, understanding these obligations is essential to avoid costly missteps and leverage available benefits. 🔹 Key Areas to Consider 1. Corporate Taxation & VAT: Norway’s corporate tax rate sits at 22%, but tax incentives are available in sectors like R&D. VAT, at 25% on most goods, requires rigorous tracking, especially for cross-border transactions.    2. Environmental & Industry-Specific Taxes: Norway’s commitment to sustainability is reflected in its environmental taxes. Companies in oil, gas, and renewables face sector-specific levies and must navigate carbon taxes and other eco-focused regulations. 3. Compliance & Reporting: Accurate and timely reporting is non-negotiable, with authorities emphasizing transparency and imposing strict penalties for errors or omissions. 🔹 How Tax Advisory Can Help A skilled tax advisor can ensure that businesses not only comply with Norway’s stringent requirements but also optimize their tax strategies to maximize benefits. From identifying deductions and credits to managing international tax issues, the right guidance aligns financial goals with regulatory expectations. 📈 Unlocking potential in Norway starts with a solid understanding of the tax landscape. With expert tax advisory, businesses can confidently navigate complexities, optimize tax positions, and build a sustainable path to growth. #TaxAdvisory #Norway #BusinessTax #CorporateTax #VAT #Compliance #Sustainability #NordicBusiness

Navigating International Tax Planning: Key Insights on U.S. LLCs and S Corps under Portuguese Tax Law 🌍💼 Struggling with how transparent entities like U.S. LLCs and S Corps are treated under Portuguese tax law? Let's break it down. 🔍 **Transparent Entities Basics** These are legal structures that allow income, deductions, and credits to flow through to the owners for tax purposes. The trick? The entity isn't taxed; the owners are. 🇺🇸 **U.S. LLCs in Portugal** U.S. LLCs are treated as transparent entities in Portugal: • Income, deductions, and credits flow through to the members. • Members pay personal income tax on their shares. 🚩 Exceptions: If the LLC has a permanent establishment in Portugal, it could be subject to corporate tax. Also, engaging in trade/business in Portugal means VAT registration may be required. 🇺🇸 **U.S. S Corps in Portugal** Similarly, U.S. S Corps are transparent entities, but with notable differences: • Shareholders are taxed on their income shares. • Permanent establishments in Portugal can attract corporate taxes, even without trade/business activity. 🚩 VAT rules apply if engaged in business within Portugal. 💡 **My Take** During my journey in international taxation, understanding such nuances has made a difference in making strategic decisions for global expansion. Informed decisions are the bedrock of optimizing international tax planning. Curious about how these differences might affect your business strategy? Let’s discuss! #taxplanning #internationaltax #USLLCs #SCorps #PortugueseTaxLaw #offshoreservices #globalbusiness>>>https://lnkd.in/gsUQj4G9

The publication of Provisional Measure (PM) 1.262 and Normative Instruction (NI) 2.228 last week, by the Brazilian Government, which introduces the OECD's Pillar 2 rules on Base Erosion and Profit Shifting (BEPS) in Brazil, represents a significant milestone in Brazilian tax legislation. The measure aims to follow the Global Anti-Base Erosion Model (GloBE) Rules, including a Qualified Domestic Minimum Top-up Tax (QDMTT). This initiative not only aligns Brazil with global tax practices but also paves the way for a more harmonized and fair approach to international corporate taxation. The introduction of Pillar 2 rules in Brazil is a much-anticipated development, reflecting the government's commitment to global convergence in the taxation of profits. The PM introduces a QDMTT, through an addition to the Social Contribution on Net Profit, applicable to Brazilian members of multinational enterprises starting January 2025. This measure aims to ensure that profits generated in Brazil are taxed fairly, minimizing the erosion of the tax base. Multinational companies with a presence in Brazil must carefully assess the potential impact of the Pillar 2 legislation on their structures. This includes: 1) mapping the existing structure to identify constituent entities that may be subject to the Pillar 2 rules in Brazil, 2) evaluating whether the relevant entities qualify for the transition period based on country-by-country reporting (CbCR) rules, 3) calculating the potential exposure to the top-up tax in Brazil, and 4) determining the need for restructuring to mitigate adverse impacts from the application of the Pillar 2 rules in Brazil. Furthermore, companies should prepare for additional compliance and reporting obligations that may arise from the new rules. (find EY Tax News Update)

KPMG: Leading the Way in EU Withholding Tax Reclaims   Over the past few months, KPMG has cemented its position as a leader in EU withholding tax reclaims, securing significant judgements from the Courts that will impact the chances of successfully recovering EU WHT reclaims. Our dedicated teams have spearheaded initiatives in key markets, and looked to progress EU WHT reclaims for our clients.   Germany: ·       KPMG Germany led litigation for two European investment fund test cases, securing a positive judgement from the German Federal Fiscal Court for claim periods pre-2018. ·       This landmark decision paves the way for clients to pursue repayments with late interest, potentially amounting to significant sums.   Netherlands: ·       Following action by KPMG in the UK and KPMG Netherlands, the European Commission has launched an investigation into actions taken by the Dutch Tax Authorities. ·       This challenges the perceived discriminatory treatment of non-resident investment funds investing in the Netherlands.   Sweden: ·       KPMG UK working with KPMG Sweden has achieved a positive decision and repayment for a US group trust (’81-100 Trust’). This is the first positive decision for a fund of this nature in Sweden. ·       KPMG Finland also led litigation resulting in a positive ruling from the CJEU in respect of a Finnish public pension plan. This ruling is expected to have wider impacts for other public pension plan claimants in Sweden under EU law.   KPMG are proud to be leading the charge in reclaiming withholding taxes under EU law, empowering our clients to recover excess withholding tax.   Contact Gohar.Khan@KPMG.co.uk or Daniel.Guilliam@KPMG.co.uk for more information.   #KPMG #WithholdingTax #EU #InvestmentFunds #EUWithholdingTax #FokusBank #ECJReclaims

#IntellectualProperty (IP) - How #TaxFunctions can maximise value with IP Regimes. Welcome to Project AITAX13’s 18th Tax Transparency Insight (Series 7 - OECD Statistics), focusing on BEPS Action 5 (Intellectual Property). QUALIFYING IP  #IP comes in many forms, from Registered IP like #Patents, #Trademarks, #Software, Copyrights and Brands, etc. to Unregistered IP like Know-How and Operating Models, However, the OECD - OCDE’s Forum on Harmful Tax Practices (FHTP), and BEPS Action 5, have introduced 2 critical concepts to Qualifying IP Regimes 1) Only Patents and Software qualifies (there is a 3rd category for SMEs - but we will ignore that for now)  2) The #NexusApproach must be applied (this requires that the tax benefits are conditional on where the R&D activity took place). QUALIFYING IP REGIMES In 2024, of the 61 #IPRegimes in place - only 43 are eligible. 10 of the 61 were abolished (in 2024). The FHTP has deemed a) 17 of these to be ’non-harmful’ IP regimes and eligible - including Ireland, Luxembourg, Malta, Switzerland, etc.  b) 26 to be ’non-harmful’ (amended) IP regimes and eligible - including Belgium, France, Netherlands, Spain, UK, etc. TAX REDUCTIONS ON IP INCOME  So ….. how much IP Income can be exempt from Corporate Tax? From 100% (full exemption) to 40% of the Tax Rate that would have been applied.  (i) 50%: The most common reduction, like Ireland, is a 50% reduction (ii) 80%: Some countries like Luxembourg offer an 80% reduction (from 24.94% to 4.99%)  (iii) 100%: And other countries, like Greece, Jordan, Mauritius, Panama, Qatar, and Turkey offer full exemption. See Chapter 6 of the OECD Tax Corporate Tax Statistics Report, prepared by Ruairi Sugrue, with input from Jessica de Vries and the FHTP for more information - and in particular Table 6.4 and 6.5 of that for a visual summary of the corporate tax benefits of IP Regimes. ABOUT PROJECT AITAX13 Financially supported by the Luxembourg National Research Fund (FNR), and assisted by the Luxembourg School of Business, the Project AITAX13 Team at the University of Luxembourg and SnT, Interdisciplinary Centre for Security, Reliability and Trust are developing AI-enhanced technology solutions to help deliver Peer Benchmarking and Early Warning Systems that will support and make life easier for Tax Functions globally - including; #MachineLearning for Tax Risk Assessment #CausalAI for Projecting Future Risk Areas #NeuralGraphNetworks to facilitate deeper dives into subsidiary legal entities and business structures #LLM and #GenAI to monitor and inform Tax Functions of #TaxRisk areas. Thanks for reading TTI 18. We will be back tomorrow with a closer look at Country by Country Reporting (BEPS Action 13) in Tax Transparency Insight 19. Best Regards, The Project AITAX13 Team www.aitax13.com #TaxTransparency #AITAX13 #BEPS13 #BEPS5 #OECD #SnT #IPRegimes #Patents

💸 Tax Implications of Using Offshore Companies 💸   Using offshore companies to reduce tax burdens seems attractive to many entrepreneurs. However, this decision comes with several serious risks. Tightening of International Tax Regulations: The Organization for Economic Co-operation and Development (OECD) has initiated the BEPS (Base Erosion and Profit Shifting) and CRS (Common Reporting Standard) projects aimed at combating tax evasion.   Tax Risks: Some offshore jurisdictions do not have double taxation avoidance agreements with other countries, so the company's income will be taxed in both jurisdictions.   Reputational Risks: The use of offshore companies is often associated with tax evasion, which can negatively impact the business's reputation. Public exposure can lead to a loss of trust from clients, partners, and investors.   Compliance and Legal Risks: Many countries are implementing measures to combat aggressive tax planning, including mandatory disclosure requirements for the ultimate beneficiaries of offshore companies. Violating these requirements can lead to serious legal consequences.\   Financial Risks: Using offshore schemes can lead to legal disputes and significant financial losses in the form of fines, penalties, and additional tax assessments. In some cases, criminal prosecution is also possible.   Alternative by Eifos Hub The use of offshore companies carries many risks and can lead to serious consequences for your business. Eifos Hub's international transfer services comply with all international standards and requirements, and our expertise in utilizing jurisdictional advantages allows for reducing tax burdens legally.   Contact us to learn more about our services and protect your business from the risks associated with offshore companies.   #EifosHub #OffshoreCompanies #InternationalTransfers #LegalSupport #FinancialSecurity #TaxPlanning

🌍 Global Minimum Tax in Brazil: Key Update for Multinationals 🌍 Starting in 2025, multinational companies with annual global revenues over EUR 750 million will face an additional social security contribution on net profits (CSLL) in Brazil. This aligns with OECD’s Pillar 2 GloBE rules, setting a 15% minimum tax rate across jurisdictions. 💡 Key Details: - Applies to "excess profits" below the 15% threshold. - Non-compliance risks fines of up to BRL 10 million. 👀 Want to know more about it? Mauricio Nucci and Rafael Maniero know the details. ➡ https://lnkd.in/ddtZjm_N #GlobalTax #BrazilTax #OECDGloBE #TaxCompliance

Did you know that Thailand offers a variety of tax incentives for businesses operating within International Business Centers (IBC)? Our latest article delves into the tax incentives available and how your business can benefit. At Benoit & Partners, we provide expert legal advice to help your business navigate the complexities of tax incentives and regulatory requirements in Thailand. Read our latest article now: https://lnkd.in/g28Y7iUw #InternationalBusinessCenter #TaxIncentives #ThailandBusiness #BenoitPartners #LegalExperts

The latest issue of our Corporate Tax News has just been published! Check out recent developments such as: ➡ #Austria's implementation of EU CbCR Directive ➡ #Bahrain's postponement of CRS and FACTA deadlines ➡ #Luxembourg's proposed corporate tax changes ➡ The #OECD's accession discussions with Indonesia and Thailand Have a look at these and many other developments via the link below 👇 👉 Follow #BDOLuxembourg #TaxNews #CorporateTax