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The Journal June 2018

Pragma Journal - June 2018
Taxation of Bitcoin

Laurent Auricoste

Until the ruling of the Conseil d'Etat on April 26, 2018, the gains from the sale of cryptocurrency units, mainly "Bitcoin", were the subject of two instructions published in the BOFIP already dating from 4 years old... These instructions provided that the gains from the sale of cryptocurrencies fell within the BICs or the NCBs depending on whether their transfer was a normal or occasional activity.

In both cases, the income from these sales supported the progressive income tax schedule (marginal rate of 45%), social security contributions CSG CRDS (now at 17.2%), and even some case the contribution on high incomes (3% or 4%).

The New Dawn of Retail: Apocalypse or Evolution?

Marvin J. Ciné

Major retailers that once reigned supreme with brick and mortar stores now face unparalleled challenges. Historically, major retailers dominated the retail industry by opening stores in the most desirable locations and offering fetching merchandise at a great value.

But, numerous trends – including a dramatic shift in shopping habits, the rise of e-commerce, the overabundance of malls and the revival of the restaurant experience – have triggered a shift in the U.S. retail landscape and led to the demise of brick-and-mortar stores.

2018 Incentives for Developing Business in Italy (Part 2)

Fabio Colombo

Italy is ranked 46 among 190 economies in the ease of doing business, according to the latest World Bank annual ratings. The rank of Italy improved to 46 in 2017 from 50 in 2016.

Regarding the distance from the border, or the so-called gap between the performance of the individual country and the best performance observed for each indicator (since 2005), Italy registers the most important leap forward among the OECD countries (passing from 71.55 to 72.70).

Does the Death of a Company Director/Founder Mean "the Death" of the Company?

Sanja Djukic

Each day of undisturbed operation of a company is of the utmost importance for business operations of the company if the same wants to be competitive and profitable in its business, considering economic circumstances and market conditions in which the competition is increasingly expressed.

It is quite a common case that a company is organized as a single-member company, i.e. that the founder and director is the same person and that one person runs the business of the entire company.

Transfer Prices: An Opportunity to Be Taken

Renato Catalán

For companies, it is essential to review cross-border operations carried out with related parties, and it is crucial to have a study on transfer prices, in order to justify them in light of current tax regulations (Article 41 E of the Tax Law to the Income), since otherwise the SII is enabled to determine the prices, values ​​or returns considered normal for the market and, in that case, for the determination of interest and fines.

In effect, the difference determined by the SII in the exercise of this power will be affected by the tax established in article 21 of the Law on Income Tax, that is, with a rate of 40%, and may also apply an equivalent fine. to 5% of the same amount.

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