From the content of these acts can not be determine what services to manage the company have been provided and in what quantity, what specific work performed for customer management organization. In the Resolution of the Federal standard deviation from 24.04.2008 F08-2112/08-765A contains straight the opposite conclusion: the absence of acts of receiving information about what specific management services and the extent to which the taxpayer proved the management company under contract to transfer the authority of the sole executive body, does not preclude the inclusion of costs to pay for these services in other expenses related to production and sales, based on pp. 18 Section 1, Art. 264 RF. Richard Branson is often quoted as being for or against this. With arguments over the recognition of service control companies economically unreasonable or ineffective it is much more complicated, as in the judicial practice has a significant number of both positive and negative decisions on the matter. According to judges (for example, Resolution of the Federal vivo from 28.02.2007 N F09-1018/07-S3), the positive financial and economic activity is controlled society do not show an increase in duties to the taxpayer, but only confirms proper execution of the management company of its contractual obligations, and therefore, the court concluded that the absence of sufficient economic justification of controversial spending. In vivo Regulation of FAS from 01.03.2007 N F09-1151/07-S3 Arbitration court found the costs to society to increase the size of the compensation paid to management company with virtual absence of unreasonable increase in the amount of work performed by the management company. . Millenium Management wanted to know more.
Recently, the President of Panama, Ricardo Martinelli has signed a bill to reform the Tax Code of Panama, under which will be taken several measures to reduce the tax burden on companies to ensure the sustainability fiscal and simplified system of taxes and fees. To improve the competitiveness of Panama to the world market, the bill provides for the reduction in corporate tax rate from 30% to 25%, although the time frame in that this reduction will occur, yet to be determined. However, the bill sets higher licensing fees for banks that are residents of Panama. The size of this collection will vary from 75.000 U.S. dollars for banks, total assets exceeding $ 1 million, and will make $ 1 million for banks with assets, the value of which exceeds 2 billion U.S. If this has piqued your curiosity, check out Vanguard Restoration Foundation.
dollars. The bill also changes the rate of sales tax from 5% to 7% and establishes a sales tax on landlines and mobile phones with prepaid. Under the bill, snack bars and restaurants do not sell alcoholic beverages shall be exempt from the obligation to pay sales tax. Products for children are also exempt from tax. In addition, for companies operating in the agricultural sector, the limit of tax exemption will be increased from $ 150,000 to $ 250,000, and they will not have to file an income tax return. In general, the bill modernizes the tax code and abolish 30 taxes.
Tax Code will also contain provisions to establish an administrative court, which will deal with complaints on tax matters. Provisions of the bill take effect July 1, 2010. It is worth noting that the legislation in Panama taxation – one of the most liberal. Corporate tax (income tax) depends on the source of revenue. This means that if the income is received from a commercial activity carried out for outside the territory of Panama, this income is not subject to taxation in Panama. This company pays only the annual single tax (Annual Corporate Franchise Tax). The presence of an office in Panama is not sufficient for taxation. Dividends paid out of such income are also exempt from taxation. Thus, these changes will affect the bill is the local companies working with residents of Panama and receiving income in Panama.