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Fidinam & Partners Newsletter - July 2021

Publications Fidinam & Partners

The Fidinam & Partners Newsletter is online! In this issue, news of Swiss and international tax advice.

In this issue:

Switzerland: Intercantonal company delocalisation and tax domicile

Inter-cantonal tax competition is a particular feature of Swiss federalism. The recent tax and AHV financing reform (RFFA) has prompted cantons to introduce measures to maintain their attractiveness to businesses internationally. Among the measures with the most immediate impact is of course the lowering of cantonal tax rates on the profits of legal entities. However, these reductions have also had the not inconsiderable effect of repositioning the cantons in
the virtual national ranking of the most competitive in terms of corporate tax burden.

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Italy: taxation of the transfer abroad of a Holding Company

In its Principle of Law No. 10/2021 of 11 May 2021, the Italian Revenue Agency provided clarifications on the taxation of migration abroad of
holding companies and, more specifically, on the possible application of the participation exemption regime to the capital gains generated by the relocation abroad of a corporate asset in which one (or more) shareholdings are included. Although the principle in question also extends the previous clarifications on the taxation of capital gains arising from the transfer of a company to cases of transfer of the registered office abroad, the same principle, however, as will be illustrated in the conclusions, still leaves open several doubts regarding its application.

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Cyprus: Implementation of the register of beneficial owners

On 16 December 2020, the Council of Ministers of the Republic of Cyprus expressed its support for the establishment of a central register of Ultimate Beneficial Owners (“UBO”) for all companies and other legal entities resident in Cyprus, appointing the Registrar of Companies and Official Receiver, (ROC) operating under the control of the Ministry of Energy, Trade and Industry, as the competent authority for the maintenance of the register and authorising it to operate the data collection through an interim electronic system. The date for commencement of data collection through an interim online portal was set at 16 March 2021. On 12 March 2021, the Registrar of Companies issued Directive 112/2021 containing guidelines for maintaining information and operating the register.

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Latin America: new tax reforms to aid consequences of Covid-19

Some Latin American countries in are addressing the COVID-19 economic crisis by proposing or implementing new tax laws. Here are some examples from Argentina, Bolivia, Chile, Colombia.

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