Spanish Tax Lawyers

List of top consulting firms 2012

2011-12-16T07:58:00.000-08:00

Following is a list of the top consulting firms around the world with such details as ranking, company name, website url, headquarters, year founded, approximate number of employees, male to female ratio, and other statistics. Being a top consulting firm do not means always prestige and do not bring quality and values automatically, but clients and job seekers of the consulting profession may be interested by these statistics.

Purpose: To summarize and provide beneficial statistical information about the consulting industry and provide quick access gateway to a list of the top consulting companies and websites.
Serving: Researchers, students, professionals, job seekers in the consulting industry and all who seek information about top consulting companies.

Disclaimer: We are not claiming any rights, responsibilites or ownership pertaining to creating, developing, designing, or programming any of the websites listed on this page. All websites listed on this page are publically available for viewing on the internet.

Rankings: Any ranking information regarding the listings above have been made by 3rd parties, organizations which make their ranking info available on public viewable pages free of charge. For this particular listing we have gathered inforamtion from various sources on the internet, including, cnn.com, vault.com, fortune.com and linkedin.com.

The 2011 Best Firms to Work For (according to Consulting Magazine):

The Best Consulting Firms to Work For 2011

Bain & Company
The Boston Consulting Group
North Highland
Point B
Deloitte Consulting
Slalom Consulting
McKinsey & Company
PwC
Booz Allen Hamilton
Huron Consulting Group
Ernst & Young
Accenture
Crowe Horwath
Monitor
A.T. Kearney

The Best Small Consulting Firms to Work For 2011

Stroud Consulting
Impact Advisors
Cask
Vynamic
Infinitive
Fitzgerald Analytics
Lenati
Jabian Consulting
PeopleFirm
HiSoft (formerly Nouveon)
Plus Consulting
Meridian Compensation Partners
Marakon
SEI
IBB Consulting Group

Rank	Consulting Firms	HQ	Industry	Type	# of employees	Year founded	Med age	Male	Fe- male
1	McKinsey & Company	Greater New York City Area	Management Consulting	Partnership	15000	1926	29	67%	33%
2	The Boston Consulting Group, Inc	Greater Boston Area	Management Consulting	Partnership	6000	1963	28	67%	33%
3	Bain & Company	Greater Boston Area	Management Consulting	Privately Held	10000	1973	28	65%	35%
4	Booz & Company	Washington DC Metro Area	Management Consulting	Privately Held	22000	1914	32	64%	36%
5	Deloitte Consulting LLP	Greater New York City Area	Financial Services	Partnership	168000	-	29	61%	39%
6	Monitor Group	Greater Boston Area	Management Consulting	Privately Held	1500	1983	29	63%	37%
7	PricewaterhouseCoopers LLP	Greater New York City Area	Accounting	Partnership	17500	-	29	59%	41%
8	Mercer LLC	Greater New York City Area	Human Resources	Public	18000	1937	34	51%	49%
9	Ernst & Young LLP	Greater New York City Area	Accounting	Partnership	144000	-	29	59%	41%
10	Oliver Wyman	Greater New York City Area	Management Consulting	Public	1001	-	30	70%	30%
11	Accenture	Greater Chicago Area	Management Consulting	Public	177000	1989	30	67%	33%
12	IBM Global Business Services	Greater New York City Area	Information Technology and Services	Public	300000	1911	34	76%	24%
13	KPMG LLP	Amsterdam Area, Netherlands	Accounting	Partnership	137000	-	30	60%	40%
14	Towers Watson	Greater Philadelphia Area	Management Consulting	Privately Held	6400	1934	34	52%	48%
15	AlixPartners, LLP	Greater Detroit Area	Management Consulting	Privately Held	900	1981	35	77%	23%
16	A.T. Kearney	Greater Chicago Area	Management Consulting	Partnership	2700	1926	30	68%	32%
17	Braxton Consulting	Eurpe & Latin America	Management Consulting	Privately Held	250	1996	31	54%	46%
18	The Parthenon Group	Greater Boston Area	Management Consulting	Privately Held	200	1999	28	62%	38%
19	Towers Watson	-	Financial Services	Public	14000	-	34	53%	47%
20	L.E.K. Consulting	London, UK	Management Consulting	Partnership	900	1983	28	70%	30%
21	FTI Consulting, Inc.	Washington DC Metro Area	Management Consulting	Public	3500	1982	32	71%	29%
22	Alvarez & Marsal	Greater New York City Area	Management Consulting	Privately Held	1600	1983	33	73%	27%
23	NERA Economic Consulting	Greater New York City Area	Management Consulting	Public	600	1961	27	61%	39%
24	Capgemini	Paris Area, France	Information Technology and Services	Privately Held	91000	1967	32	77%	23%
25	Navigant Consulting, Inc.	Greater Chicago Area	Management Consulting	Public	2500	1983	32	62%	38%
26	Huron Consulting Group	Greater Chicago Area	Management Consulting	Public	2000	2002	30	61%	39%
27	Hewitt Associates	Greater Chicago Area	Outsourcing/Offshoring	Public	25000	1940	32	55%	45%
28	Roland Berger Strategy Consultants	-	Management Consulting	Partnership	2100	1967	28	72%	28%
29	ZS Associates	Greater Chicago Area	Management Consulting	Privately Held	1400	1983	27	72%	28%
30	CRA International, Inc.	Greater Boston Area	Management Consulting	Public	800	1965	33	65%	35%
31	Arthur D. Little	Paris Area, France	Management Consulting	Privately Held	1000	-	30	75%	25%
32	Kurt Salmon Associates	Greater Atlanta Area	Management Consulting	Public	700	1935	33	63%	37%
33	LECG	San Francisco Bay Area	Management Consulting	Public	1200	1988	34	69%	31%
34	Gallup Consulting	District of Columbia	Management Consulting	Privately Held	2000	-	27	60%	40%
35	Aon Consulting Worldwide	Greater Chicago Area	Management Consulting	Public	6300	1983	36	52%	48%
36	BraxtonTechnology	Europe, Asia & Latin America	Technology Consulting & Services	Privately Held	219	2005	26	74%	26%
37	Cornerstone Research	San Francisco Bay Area	Legal Services	Privately Held	201	1989	27	61%	39%
38	Corporate Executive Board	Washington DC Metro Area	Management Consulting	Public	2000	1979	28	50%	50%
39	Hay Group	Greater Philadelphia Area	Management Consulting	Privately Held	2600	1943	32	47%	53%
40	Analysis Group, Inc.	Greater Boston Area	Management Consulting	Privately Held	500	1981	30	62%	38%
41	Milliman, Inc	Greater Seattle Area	Insurance	Privately Held	2000	1947	35	62%	38%
42	Zolfo Cooper	Greater New York City Area	Financial Services	Privately Held	75	-	31	67%	33%
43	Mars & Co	-	-	-	-	1979	-	-	-
44	The Advisory Board Company	Washington DC Metro Area	Hospital & Health Care	Public	1000	1979	28	43%	57%
45	Putnam Associates	Greater Boston Area	Management Consulting	Privately Held	50	1988	26	64%	36%
46	First Manhattan Consulting Group	Greater New York City Area	Management Consulting	Privately Held	51	1980	26	76%	24%
47	IMS Health Incorporated	Greater Philadelphia Area	Pharmaceuticals	Public	10000	1954	34	57%	43%
48	Buck Consultants	Greater New York City Area	Human Resources	Public	1900	1916	38	55%	45%
49	Giuliani Partners LLC	Greater New York City Area	Management Consulting	Privately Held	11	2002	45	79%	21%
50	Archstone Consulting	Greater New York City Area	Management Consulting	Privately Held	250	2003	34	63%	37%

Knowledge-related Motives.

2011-03-14T07:50:00.001-07:00

Recent research findings suggest that knowledge assets both push and pull SMEs into international markets.There are also related findings from a number of OECD countries (Sweden, Ireland, and Canada) and non-OECD economies (Chile, India and Indonesia) on the internationalization triggering effects of knowledge aspects, including R&D investment, innovation capabilities, unique product or technology, management, and language skills; and firm resource base, as indicated by such proxies as size, age, and experience. The push ‟dimension pertains to the importance of managers”previous international experience and related management capacity factors, as observed in studies among Canadian firms, Spanish firms, and Swedish firms. Search for knowledge assets may also pull SMEs into international markets, as suggested by Kocker and Buhl's findings that firms internationalize to obtain missing know-how required to maintain their lead in technological development.

European Union Direct Taxes

2011-02-09T08:01:00.000-08:00

Permanent Establishment is a vital concept in international taxation. While for direct taxes, it is mainly defined by the OECD Model Convention, the European VAT Directive and its implementing Regulation provide an EU-wide approach for VAT.
Difficulties arise as terminology and definitions in indirect and direct tax diverge. Moreover, countries have implemented and interpreted the EU and OECD rules in a different way, impacting on issues like cross-border reorganisations, transfer pricing, taxation of dividends and interest and royalties, tax residence, temporary and permanent transfer of assets, place of supply and VAT liability.
In both direct and indirect tax, the concept of Permanent Establishment has undergone very recent changes: The 2010 changes to the OECD Model Convention and Commentary, and in particular the new Art. 7, will be adopted in national law, as speakers from the Netherlands and Germany will report. The effect of the new definition on treaties with other countries will also be considered.
Some of this topic is addressed in the new book "European Union Direct Taxes", by the International Tax Professor Salvador Trinxet Llorca.
In indirect tax, the current more important issue is the practical consequences of the adoption of the Regulation implementing the EU VAT Directive in January 2011.

Internationalization

2010-12-20T04:31:00.001-08:00

internationalization and international entrepreneurship among small and medium-sized enterprises (SMEs) has remained a topic of considerable contemporary relevance, principally owing to the observed growth effects of cross-border venturing, and the demonstrated capacity of SMEs to drive economic development at national, regional, and global levels (European Commission, 2007). This realisation was at the heart of the 2007 OECD-APEC study on Removing Barriers to SME Access to International Markets, which provided general findings on the major barriers to SME internationalization as perceived by SMEs and policymakers in OECD and APEC member economies.1 The need to obtain a greater depth of understanding and an updated view of the issues raised by the OECD-APEC study provided a raison d'être for this follow-up project. Other value adding features include the additional focus on motivations for SME internationalization ; the coverage of recently available documentation from economies involved in the OECD enlargement (Chile, Estonia, Israel, Russia, and Slovenia) and enhanced engagement process (Brazil, China, India, Indonesia, and South Africa); and the sub-national and sectoral insights offered on SME internationalization barriers, motivations and support programs.

OCDE prerrogatives for internationalisation on SME

2010-12-16T04:43:00.001-08:00

i. To analyse in-depth the most significant barriers to SME

internationalisation identified from the 2007 OECD-APEC sponsored research on this theme, with a view to uncovering new insights into the nature of these top barriers;

ii. To review recent work pertaining to factors that drive or motivate the internationalisation of SMEs; and

iii. To develop a deeper understanding of the current programs for SME internationalisation, particularly the specific measures aimed at addressing the top barriers identified.

To provide an updated appreciation of pertinent aspects of SME internationalisation, the report reviewed the post OECD-APEC survey evidence on the top barriers, drivers and support programs across OECD and APEC member economies and other economies involved in the OECD enlargement and enhanced engagement processes. This has yielded important longitudinal insights, thereby indicating that support programs are appropriately focused on the most resilient and enduring of the factors affecting SME internationalisation.

To ensure a greater depth of understanding on SME internationalisation barriers, this study focused on the top four barriers identified by the OECD-APEC study as being by far and away the most serious impediments to SME internationalisation (see Table 1). These include 1) Shortage of working capital to finance exports; 2) Identifying foreign business opportunities; 3) Limited information to locate/analyse markets; and 4) Inability to contact potential overseas customers. A fifth barrier, „lack of managerial time, skills and knowledge‟, is additionally examined. The reasoning is threefold: one, this reflects the importance of this barrier in the Member Economy survey (see Table 2); two, the consistently highlighted primacy of managerial factors in previous relevant global surveys; and three, the widely acknowledged importance of skilled human resources in all areas of economic activity, including market innovation.

An opinion from one of our readers commenting the news from Yahoo

2010-12-09T04:13:00.001-08:00

What difference would it make to our standard of living if EVERYONE paid an increase in taxes?. Several people are tired of the argument over tax the rich but not the middle class. Social Security recipients have given up the COLA for two years. Who else in the country has already given up that much? Why not let the Bush tax cuts expire for everyone? Returning taxes to the Clinton era levels might return us to the Clinton era prosperity levels. It is worth a try since nothing we have done since the Clinton era has worked. America has been in decline since he left office.

Another blog where you'll find International Tax information is International Tax Spain

Proposta da Comissão

2010-12-01T04:33:00.001-08:00

O objectivo da proposta consiste em estabelecer um procedimento que permita à Comunidade avaliar se existe um interesse comunitário suficiente para concluir acordos bilaterais propostos com países terceiros e, na ausência do mesmo, autorizar os Estados-Membros a concluírem estes acordos com países terceiros em certos domínios da cooperação judiciária em materia civil e comercial que são da competência exclusiva da Comunidade.

Uma vez que a autorização concedida aos Estados-Membros constitui uma derrogação à regra segundo a qual a Comunidade tem competência exclusiva para concluir acordos internacionais sobre estas matérias, o procedimento deve ser considerado uma medida excepcional e ter um âmbito de aplicação e uma duração limitados.

Propõe-se limitar o procedimento em causa às questões sectoriais relacionadas com as matérias matrimoniais, a responsabilidade parental e de obrigações de alimentos, por um lado, e com a lei aplicável às obrigações contratuais e extracontratuais, por outro. A proposta em anexo diz respeito ao segundo domínio.

A Comissão propõe as garantias a seguir descritas com o objectivo de preservar o acervo comunitário, incluindo a integridade do sistema comunitário no domínio em causa.

O procedimento baseia-se na notificação prévia do projecto de acordo pelos Estados-Membros que pretendem obter uma autorização para renegociar e concluir um acordó com um país terceiro com base em condições específicas a avaliar caso a caso.

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Behavioral marketing by International Lawyers

2010-12-01T04:27:00.001-08:00

EXTERNAL AND INTERNAL COMMUNICATIONS BELONG TOGETHER

When Starting a business behavioral marketing also fosters a worldwide exchange of information internally as experienced by International Lawyers. Knowledge of global events and issues is only useful to customers if it is available around the world. When it comes to efficient marketing, Freshfields combines specialization with the advantages inherent in a large-scale company. For example, one of its objectives is to represent clients who were acquired in the finance or corporate sectors in the labor law area, too. Cross-selling is also used as a marketing support tool—if cases span sectors, Freshfields will offer a price discount. Clear positioning is necessary and becomes all the more difficult as more companies seek it. And this dictum applies to Freshfields and its competitors as it does to every service industry. "There's no sense in sprucing up a commercial if you're putting out the same message as your competitors," says Kotler. In other words, "focus" will be the buzzword in future, particularly within the service sector. Looking at seemingly straightforward services, two-way communications (preferably demand-oriented) with the customer are becoming more significant, and that extends all the way to complaint management. The Pizza Hut franchise chain, for example, prints its hotline number on every pizza box to take calls from unsatisfied customers. The franchise manager then has 48 hours to resolve the problem. The luxury-hotel chain Hyatt is also known for its fast response times to customer complaints— you can even send them to management using the in-room television and its remote control.

DOES DEMARKETING CREATE A NEW SENSE OF TRUST?

For Kotler, such trust-enhancing measures are just a small part of the imminent marketing revolution. "We want to develop methods that will actually reduce an otherwise continually increasing demand," is Kotler's position, which is surprising from a marketing perspective. The essence of this approach is to perceive "demarketing" as a source of trust. According to this notion, keeping certain types of customers away from your product may actually be a positive marketing approach. One might be inclined to think that this attitude is naïve. But that's not necessarily so, says Kotler, although it does have to be grasped properly in-house. "First, one has to identify values. And then one has to hire people who believe in these values and embody them." Crises always represent crucial tests for Kotler's value-based marketing. For example, in difficult times, how do companies deal with clients that are late with payments? John Deere, the US-based agricultural equipment manufacturer, may serve as a role model, he says. "John Deere helped farmers, while rival International Harvester unceremoniously seized its machines." John Deere's level of generosity is rarely found among service providers, even though times of crisis are a perfect opportunity to create new customer loyalty. Kotler recommends to banks and insurance companies in particular that they fully understand the acute problems some of their customers may be facing. He also thinks that their advertising requires a different tone. "The financial crisis compelled many service providers to rethink their marketing and advertising strategies." Solidarity is the new mantra, he says. For example, Morgan Stanley's European advertisements promote their high equity ratio compared with other banks. "They're probably doing the right thing," Kotler explains "Especially if other banks have to address some rather uncomfortable questions on this point."

IT'S EASIER TO SEPARATE THE GOOD GUYS FROM THE BAD GUYS

These questions are certainly being asked, not just in the industry but publicly as well when starting a business. The growth of social media makes companies an ongoing subject of debate. Internet portals where consumers can discuss their experiences make it "easy these days to differentiate the good guys from the bad guys." From a marketing perspective, turbulent times are actually good times, according to the tenor of Kotler's new book Chaotics. "Ryanair is an example that says a few things about seizing an opportunity that arose from the crisis," he states. During the crisis, Ryanair ran a massive advertising campaign and thereby tapped customers' magnified price consciousness. The outcome was a substantial gain in market share.

KOTLER'S "KEY" POINTERS FOR SERVICE MARKETING MANAGERS. "QUALITY IS KING"

Nowadays, customers have precise expectations of services they utilize. Social media platforms such as Facebook increase transparency, which means customers now define quality.

"BUILDING THE MARKETING ORGANIZATION"

Building up long-term customer relationships is more difficult today than ever before. Customers are fickle. Marketing must quickly adjust to new situations and therefore needs to have, first and foremost, a very flexible organization.

"THE FIRM CAN'T BE ALL THINGS TO ALL PEOPLE"

Opportunities for service companies to differentiate themselves from one another are on the rise. They can be socially oriented or maintain higher environmental standards than their competitors. It's all about accessibility. The physical presence remains irreplaceable. For example, online banks in Europe are currently setting up "finance lounges" in major cities.

More about the International Lawyers that you will need to start a business on International Lawyers to start a business

“All muscle and no fat”

2010-11-29T05:01:00.001-08:00

"All muscle and no fat"

Marketing is becoming more important in the professional services industry and the legal consultants . But how does one market non-visible products such as the International Lawyers? According to expert Philip Kotler an international lawyer, you use credibility. Revealing a previously unseen socially conscious side, he recommends combining sustainability and smart communications.

The Dow Jones Sustainability Indexes are the conscience of the investment industry. Companies identified as "supersector leaders" not only receive the blessing of critical customers, they will also be among the favored billion-euro funds that focus on ethical conduct. As a result, sustainability has become a firm part of the marketing strategy of global companies. This used to apply especially to manufacturers of consumer goods—until now, at least.

Now, high-end service providers might want to rethink the situation. At least, that's what marketing guru Philip Kotler is urging. In a meeting with think:act, he recommends that service companies change their way of thinking because what they really do is deliver trust. However, they first need to earn that trust via responsible conduct. Kotler is at the forefront of the reform movement, even though he previously represented more traditional marketing approaches. In his book Corporate Social Responsibility, he examines how companies perceive the obligation of giving back to society. When American Express promotes education and tourism projects in developing countries, or when IBM participates in social issues, these actions contribute to the companies' authenticity, he says. "It's always better if a company draws attention to itself through its philanthropic projects," rather than by means of traditional product advertising. In principle, long-term service marketing begins with a company's core processes. The public will see right through any "greenwash."

Consumers and customers are no longer passive participants in the marketing process: people will find out if a European logistics company is marketing itself as green while at the same time running poorly maintained, pollution-spewing trucks in its transportation operations. On the other hand, a substantial social commitment offers more than just external gains. It makes companies smarter by creating dialogue platforms. They increase inhouse expertise and ensure that management understands not just financial markets but also social trends. However, the desire to hold a long-term position is crucial, especially in this competition for dialogue platforms. And this is where marketing, which often pursues short-term effects, needs to rethink its game, as exemplified by promoting social initiatives. Kotler warns about reducing socially oriented commitments too quickly in turbulent times: "Management does save money in the short term, but will lose it again in the long term once the situation improves." Companies that abandoned community organizations when these needed support most desperately will see interest groups and customers losing trust in them. Kotler is convinced that services require at least as much marketing substance as tangible products. In fact, the latter are fairly easy to advertise. Things get a little more complicated when it comes to corporate consulting or internationally active commercial law firms, like the Lovells and Linklaters of the world. For them, close personal relations with clients are crucial. This skill can be acquired and it goes by the name of "behavioral marketing." Freshfields Bruckhaus Deringer is one law firm that demonstrates how the concept works in practice. It draws clients by having teams that specialize in various industry sectors. Team members must not only be right up-to-date with the latest legal news developments, they must also be proactive in keeping the client informed. Thus, in a broader sense, every good international attorney also serves as the client's counsel.

Expatriates Moving to countries which are not prescribed territories for expatriates

2010-11-26T03:19:00.001-08:00

Expatriates can move to countries which are not prescribed territories

According to the savings directive, you do not need to make a report if a UK passport holder moves permanently to a country which is not a prescribed territory, although the payment may be reportable under S17 or S18.

However, if an individual falling under the general rules and living in the UK (or in another Member State) and who has a passport or ID card issued by a Member State other than the UK moves to a country not covered by the scheme and does not produce a certificate of residence for tax purposes from that country's authorities, a report will be required. You will need to update your records to include all the necessary information.

This is because the country of residence for reporting purposes will be the Member State which issued the individual's passport or identity card.

For example, a paying agent makes a savings income payment to a Spanish passport holder living in the UK with whom he has a contractual relationship entered into on or after 1 January 2004. The individual moves to Iceland, but does not obtain a certificate of tax residence from the Icelandic authorities.

The country of residence for reporting purposes is now Spain. Therefore the paying agent will need to obtain and verify the individual's name and address and either the individual's TIN or date and place of birth.

When an individual moves during the year, there may be more than one country of residence and address for the same reporting period.

As long as you report consistently, you may report either the address and country of residence at the time the savings income payment is made, or the address and country of residence at the end of the reporting year (5 April).

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Moving from one prescribed territory to another

2010-11-25T02:35:00.001-08:00

Moving from one prescribed territory to another

An International Lawyer is intended to study all the European Directives. According to the Savings Directive, "If an individual, who is currently reportable because they live in one prescribed territory, moves to a different prescribed territory, you may need to update the address and country of residence information. If the individual moves to a Member State, you may also need to obtain and verify a new TIN, since the information you hold may be out of date (because the TIN to be reported is the TIN issued by the Member State in which the individual resides). If you cannot obtain the new TIN you should obtain, verify and report the date and place of birth.

For example, a UK paying agent makes a savings income payment to a Spanish passport holder whose permanent address is in France. The paying agent has a contractual relationship made on or after 1 January 2004 with the individual, who moves permanently to Germany.

The paying agent currently reports the payee's name, address, country of residence (France) and the French TIN. If the payee moves to Germany, the paying agent will need to report the payee's name, new address and country of residence (now Germany). Since it is a relationship made on or after 1 January 2004 he will also – if Germany is now the country of tax residence - need to obtain and verify the new German TIN or, if it is not available, the date and place of birth."

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Moving from the UK to a prescribed territory

2010-11-24T03:10:00.001-08:00

Moving from the UK to a prescribed territory

According to the Savings Directive, "If a UK individual changes address to a prescribed territory you will need to report on the basis of the new address. This may mean you need to obtain additional information and/or update your system.

For example, a UK paying agent pays savings income to an individual who lives in the UK. This is not reportable under the scheme. He has a contractual relationship made on or after 1 January 2004 with the individual.

If the payee moves to Spain, they will become reportable and the paying agent will need to update his records to fulfill his obligations under the scheme. Since he has a relationship which began on or after 1 January 2004 with the individual, he will also need to verify the name and address in addition to obtaining and verifying the TIN or the date and place of birth.

Where both the identity and UK address were verified to KYC standards, and the contractual relationship began after 1 January 2004, subsequent changes can be 'self certified' in accordance with paragraph 183.

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Collective investment funds: income realised at sale or redemption of fund units

2010-11-23T02:46:00.001-08:00

Guidance Notes vs. 5 - draft vs. 8 - cleaned up version

According to the Savings Directive, "Savings income also arises when units or shares in a collective investment fund are sold to a paying agent (or a receiving agent) or redeemed by the fund. This is analogous to the inclusion of accrued interest in the sale or redemption price of a security (see paragraphs 97 to 103 above).

Savings income only arises under this heading if the fund has invested more than 25% of its assets directly or indirectly (via other collective investment funds or residual entities) in money debts. Up to and including 31 December 2010 the figure was 40% of its assets. This applies to all funds and does not depend on any requirements of the territory in which the fund is established.

A In determining whether a sale or redemption of units or shares in a collective investment fund is reportable under these arrangements the information described at paragraphs 121 – 123 below may be used and relied upon. The paragraphs 118B – below provide additional guidance for particular circumstances if need be.

Where a fund has historically invested more than 40% of its assets in money debts it is unlikely to be affected by the reduction of the percentage to 25% from 1 January 2011 – by definition income realised at sale or redemption will be reportable throughout.

However if a fund under its rules or instrument of incorporation (see 121 below) or actual composition of assets (see 122 below) operates so as not to pass the 40% threshold, it will need to ensure, as soon as practical, after 1 January 2011 that its asset holding in money debts (including holdings of grandfathered bonds) is reduced so as not to pass the 25% threshold if the intention is that it continues to operate so that sales/redemptions will not be reportable under these regulations.

Providing a fund does so reduce its holdings in money debts sales/redemptions will not be reportable as savings income throughout.

In this context a fund will be regarded as having acted as soon as practical if by the start of the first accounting period commencing on or after 1 January 2011 or the 30 April 2011, whichever is the later, its assets in money debts do not pass the lower threshold.

This period should facilitate the necessary changes to be made and enable the fund to operate as it intended.

If the fund has met the old threshold under its rules but decides not to meet the new lower threshold then savings income will arise on a sale/redemption once its assets in money debts pass the 25% threshold."

Guidance Notes vs. 5 - draft vs. 8 - cleaned up version

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The big questions for many managers: Should you get off the plane?

2010-11-22T01:55:00.001-08:00

In some cases, these risks can impact the subsidiary organization's directors, officers and managers. In others, executives from the home territory may be at risk: Some have even been known to question if they should get off the plane in countries in which their company's subsidiary may be involved in a legal tangle, she says. To avoid potential problems, Colwell tells executives to consider D&O coverage for offshore subsidiaries placed by the corporate headquarters, or as local laws require, placed in the subsidiary's country. An important consideration for buyers is to make sure the company's D&O broker has access to partner brokers abroad. "We need insurance policies and programs that can adapt to various indemnification scenarios, so that individuals are protected in all jurisdictions." Hartmut Mai, the Global Head of Financial Lines at Allianz Global Corporate & Specialty, a major provider of D&O insurance, says policies used to have global reach but are now increasingly subject to local regulations. He recommends one-stop shopping for D&O coverage at larger insurance providers that can meet needs in all territories and advise on peculiarities. Mai also advises that managers who are trying to steer their company's D&O program insist on close contact with insurers to foster a mutual understanding of risk exposure. "Keeping in constant communication is not just good for underwriters, it's also good for the client because the client begins to understand how the underwriter thinks and what he is looking for in the risk assessment process," says Mai. David Walters, who manages the commercial D&O business of Chartis Insurance in the UK and Ireland, a part of the former AIG and one of the world's largest D&O insurers, also recommends that companies communicate frequently with their insurance brokers and insurers about business developments that could potentially change a company's risk profile.

According to Walters, companies should treat their D&O providers just like one of their stockholders—and for good reason: "At the point of crisis, if the communication has been two-way and open, a solid relationship would be in place to back up the claims process."

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REVERSE TAKEOVERS IN THE PLUS MARKET (LONDON)

2010-11-19T00:35:00.001-08:00

Greener House Investments Plc also recently completed a reverse takeover, acquiring Fresh T Limited, a privately owned company specialising in Software as a Service.

Following the reverse takeover, the enlarged group was renamed

FreshTL Plc was readmitted to the PLUS markets.

Hanseatic & Baltic Properties Plc

was suspended from the PLUS markets in January 2010 in anticipation of a reverse takeover of United Sino, a Libyan property development company. However, the deal was terminated in April citing "Sino were unable to guarantee raising sufficient funds for us to satisfy ourselves that the enlarged group would have had sufficient working capital to carry out the projects." Hanseatic & Baltic Properties Plc has been restored to trading on PLUS.

Award International Holdings plc recently completed a reverse takeover, acquiring a full service digital marketing specialist, Fuse 8, for £5m which will be satisfied by the issue of 10,215,000 consideration shares.

The directors had examined many acquisition opportunities since Award became an investment company and believe that Fuse 8 presented an exciting prospect for existing Shareholders.

Following the reverse takeover, the enlarged company was renamed Fuse 8 Plc and listed on the AIM Market.

more information on:

http://foreign-tax.blogspot.com/

http://international-tax-lawyer.blogspot.com/

Clean or dirty Cash Shells in the Plus Market Exchange

2010-11-18T03:43:00.000-08:00

Cash shells can be "clean‟ purpose built with a fresh pool of capital with the aim of finding a project seeking capital to acquire.

Investors in the shell are backing the board to spend their cash wisely and target profitable companies or companies that can achieve capital growth, even though they have not yet secured a deal.

Alternatively, they can be "dirty‟ companies with a stock market quote and some funds whose previous business failed and have undergone a restructuring and a formal arrangement to eliminate all the company‟ old liabilities.

More about the Plus Market Exchange on:

http://international-tax-lawyer.blogspot.com/

http://foreign-tax.blogspot.com/

La recuperación del IVA de las facturas incobrables

2010-11-15T01:03:00.001-08:00

En España, el procedimiento de recuperación de las cuotas del IVA correspondiente a facturas impagadas por los clientes requiere por parte de la empresa de una serie de requisitos formales, materiales, temporales y subjetivos establecidos por la normativa del impuesto. Un adecuada gestión del procedimiento de recuperación del IVA de las facturas impagadas por los clientes puede favorecer el cobro del propio crédito y la recuperación del IVA ingresado en las facturas incobrables.

Más información sobre recuperación del IVA en http://fiscalidadinternacional1.blogspot.com/

El Sandwitch Holandés

2010-11-15T00:46:00.001-08:00

Introducir el paso por los Paises Bajos entre dos sociedades es lo que se llama el Sandwich Holandés.

Irónicamente, el "Sandwich no deja migajas que degustar" como dijo un empleado de Tax Research LLP.

La compañía Microsoft, que está basada en Redmond, WA, también ha utilizado una estructura de Doble Irlandés según los mismos registrs de esta en el extrangero. A Forest Laboratories Inc, fabricante del antidepresivo Lexapro, las cosas también le van bien según la agencia de noticias Bloomberg News. Esta empresa farmacéutica de Nueva York, declara la mayoría de sus beneficios en el extrangero, aunque la mayor parte de sus ventas sean dentro de los Estados Unidos. Sus precios de transferencia están siendo auditados por el IRS.

Desde los años 60, Irlanda a perseguido una estrategia de incentivos fiscales para atraer multinacionales. Otro aspecto menos comentado es que permite a las sociedades transmitir los beneficios fuera del país sin demasiadas consecuencias fiscales.

"Sacando los provechos fuera"

Para que no se acumulen todos los beneficios en Irlanda, hay que sacarlos fuera de esa jurisdicción de alguna manera fácil, y eso, se hace a través de Bermuda.

Irlanda siempre ha buscado asegurar que los beneficios cobrados en Irlanda reflejen en su totalidad la funciones, bienes y riesgos localizados ahí por grupos multinacionales.

Una vez que los beneficios no americanos de google llegan a Bermuda, es dificil seguirles la pista. Su subsidiaria en ese país, cambió su forma legal de organización en 2006 convirtiendose en una LLC. Bajo las reglas irlandesas eso implica el no requisito de transferir información fiscal al país de orígen.

Diferida indefinidamente

Técnicamente las multinacionales que transfieren los beneficios al extrangero, evitan los impuestos permanentemente. O hasta que deciden devolver al país de orígen los beneficios. A la práctica, pocas veces se repatrían porciones significantes evitando así indefinidamente los impuestos. Según Michelle Hanlon, una profesora de contabilidad del Massachusetts Institute of Technology.

En 2009 el departamento de tesorería americano, propuso reducir las tasas en los pagos entre sociedades americanas y sus subsidiarias.

Los oficiales de tesorería estimaron que el cambio reportaría unos beneficios de $86.5 billones en nuevos ingresos para los próximos diez años, pero ciertas compañías en el Congreso se mostraron contrarias a la medida como General Electric co, los fabricantes de cosméticos Johnson & Johnson y Starbucks Corp, según unos informes hechos por la Ong Center for Responsive Politics.

Google y Transfer pricing

2010-11-12T05:17:00.001-08:00

Precios de Transferencia.

En febrero pasado, la administración de Obama, propuso medidas para cambiar la dinámica de la transferencia de beneficios offshore. En su propuesta se incluía destinar $12 billones a tal efecto en los siguientes 10 años. Mientras estas propuestas no avanzan en el Congreso de Estados Unidos, el IRS dijo en abril que dedicaria más agentes y abogados en cinco de lass más grandes soluciones de

Longitud de Brazo

La transferencia de beneficios normalmente empieza cuando compañías como Google venden o licencian derechos extrangeros sobre propiedad intelectual para desarrollar en los Estados Unidos a un subsidiario sito en un país con una fiscalidad más beneficiosa. Esto significa que los beneficios en el extrangero basados en tecnología se atribuyen a una unidad offshore, no a la empresa madre. Bajo la jurisdiccion americana, los subsidiarios deben pagar precios de longitud de brazo por esos derechos, la cantidad que una empresa totalmente ajena, pagaría.

Como esos pagos contribuyen a los beneficios taxables, la compañía madre tiene un incentivo a establecerlos cuanto más bajo mejor. Recortando los gastos de la subsidiaria, efectivamente se trasladan los beneficios al extrangero.

Despues de tres años de negociación, Google recibió la aprovación del IRS en 2006 para el pacto de precios de transferencia, acorde con las cuentas en el Securities and Exchange Commission.

El IRS dio su consentimiento en un pacto secreto conocido como un pacto de precios avanzado. Google no discutiría el precio bajo ese pacto, lo que daba licencia a los derechos de su tecnología de búsqueda y publicidad y otras propiedades intangibles para Europa, Medio Oriente y Africa. A eso se le llama Google Ireland Holdings, según un experto ene l tema.

Oficina de Dublín.

El licenciado a su vez es propietario de Google Irlanda Limited, que emplea al menos a 2,000 personas en un edificio de cristal en el centro de Dublin, a una manzana de distancia del Grand Canal de la ciudad. El subsidiario de Dublin vende propaganda globalmente y según google obtiene el 88% de sus $12.5 billones de ventas no americanas anualmente.

Hacer que los beneficios sean en Irlanda ayuda a Google a evitar el impuesto de retna en Estados Unidos, donde la mayor parte de su tecnología fue desarrollada. El pacto también reduce la responsabilidad de la compañía en otras jurisdicciones europeas con jurisdicciónes fiscales poco favorables.

Los beneficios pero, no se quedan en la filial de Dublín, que reportó beneficios antes de las tasas de menos del 1% en ventas en 2009 según los registros Irlandeses. Esto en mayor parte ocurro porque pagó $ 5.4 billones en royalties a Google Ireland Holdings que tiene el centro de gestión efectiva en Bermuda, según los registros de la compañía.

Directores de firmas legales.

Esta entidad dirigida en bermuda es propiedad a partes iguales de los subsidiarios de Google que se nombran como directores a dos abogados y un manager de Conyers Dill & Pearman, una firma legal de Hamilton, Bermuda.

Los asesores fiscales le llaman a esto una solución de Doble Irlandés porque se basa en dos compañías irlandesas. Una que paga royalties para el uso de la propiedad intelectual, generando gastos que reducen los beneficios taxables irlandeses. Y la otra recolecta los royalties en un paraiso fiscal como Bermuda, evitando los impuestos Irlandeses.

Para mantenerse fuera de la retención fiscal, los pagos desde Google Dublin no van directamente a bermuda. Hacen primero una parada en los Paises Bajos evitando así responsabilidad porque las leyes fiscales irlandesas eximen ciertos royalties de compañías que sean de miembros de la Unión Europea. Así, los pagos primero van a la sociedad holandesa, Google Netherlands Holdings B.V. Que paga un 99.8% de lo que recolecta la entidad en Bermuda. Como curiosidad la sociedad basada en Amsterdam no tiene ni un solo empleado.

Más información en fiscalidadinternacional1.blogspot.com