Portuguese Court’s decision in transfer pricing dispute relating to inter-company loan and management fees
The arbitration administrative court in Portugal recently ruled in favour of the taxpayer in a dispute with the Portuguese Tax Authorities (TA) in respect to the application of the arm’s length principle to inter-company loan and management fee
See MoreUnited States: IRS publishes quarterly list of individuals who have expatriated.
The US Internal Revenue Service has published a quarterly notice with a list of US citizens and long-term US residents who have renounced their citizenship or residency for US federal tax purposes. The Notice is dated 29 January 2013, and is based
See MoreJapan: For 2013 tax reform proposals
The Tax Commission of Japan has submitted 2013 tax reform proposal on January 29, 2013 upon approval by the Cabinet. The suggested reform will be submitted to the Diet during February 2013 for consideration. The proposed main changes are summarized
See MoreTreaty between Finland and Uruguay enters into force
The Income and Capital Tax Treaty between Finland and Uruguay entered into force on 6 February 2013. The treaty generally applies from 1 January 2014. The treaty is based generally on the model tax conventions of the OECD and UN. The definition of a
See MoreChile: New Transfer Pricing Compliance Requirement
A new transfer pricing compliance requirement has been introduced in Chile by Resolution No. 14 of 2013. According to the new rule Chilean taxpayers are required to file a Transfer Pricing Annual Informative Return (‘TP Return’) for calendar
See MoreAustralia: New Transfer Pricing Legislation
On 13 February 2013, the Federal Government introduced legislation on 13 February containing new Australian Transfer Pricing Laws. These are largely consistent with the Exposure Draft (ED), released in November 2012. The new enactment adjusts
See MoreTreaty between US and Poland signed
United States has signed an Income Tax Treaty (2013) with Poland on 13 February 2013 which will replace the existing agreement, signed 1974. The new treaty provides for reductions in withholding taxes on cross-border payments of dividends,
See MoreRussia: Amendments to Tax Code regarding corporate property tax
Russian Federal Law No. 202-FZ, issued on November 29, 2012, amended the Tax Code by introducing additional exemptions from corporate property tax. From January 1, 2013, the categories of assets not subject to corporate property tax include movable
See MorePhilippines: New Transfer Pricing Regulations
The Philippines’ Secretary of Finance issued Revenue Regulations (RR) No. 02-2013 – the transfer pricing regulations – on 23 January 2013, which became effective from 9 February 2013. The new regulations provide guidance in applying the
See MoreNetherlands: New income tax allowances and tax rates for 2013 published
The 2013 income tax rates and allowances which apply at the BES Islands were published In the Official Gazette of 5 February 2013, Decree No. DB 20103-38M of 30 January 2013. For the year 2013 the tax rate for income from a substantial interest is
See MoreKorean government releases revised tax reforms enforcement ordinance
The Ministry of Strategy and Finance (MOSF) on 17 January 2013 announced that the revised tax reforms enforcement decree would be released in mid-February. This decree will provide for the enforcement of amendments made to a number of tax laws,
See MoreIndia: General Anti-Avoidance Rule For 2014
The General Anti –Avoidance Rule (GAAR) of India had been scheduled to be implemented from April 2014. After further consultation the provisions will however now come into effect from April 1, 2016 and these provisions would be used to target only
See MoreOECD: Treaty Relief and Compliance Enhancement (TRACE) system released
In 2006 the OECD’s Committee on Fiscal Affairs and the Business and Industry Advisory Committee (BIAC) set up an informal consultative group of government and business experts to work on improving the process by which portfolio investors may gain
See MoreOECD invites comments on the draft International VAT Guidelines
The OECD has issued a draft consolidated version of the international VAT/GST Guidelines with an invitation for public comment on four new draft elements of the Guidelines. The new elements are a preface to the Guidelines; the core features of VAT
See MoreOECD publishes comments on the revised discussion draft on beneficial ownership
The OECD has published the comments received from interested parties on its revised proposals in respect of the meaning of “beneficial ownership” for the purposes of Articles 10 to 12 of the OECD Model Tax Convention. The comments relate to the
See MoreOECD issues report on base erosion and profit shifting
A report on base erosion and profit shifting (BEPS) commissioned by the G-20 has been published by the Organization for Economic Cooperation and Development (OECD). The report has already been considered by the G-20 at its mid-February meeting. The
See MoreOECD publishes comments received on the revised emissions trading discussion draft
On 19 October 2012 the OECD released a discussion draft on tax treaty issues relating to emissions permits and credits. Comments from interested parties were invited by 15 January 2013 and these comments have now been published on the OECD
See MoreOECD publishes comments on permanent establishment discussion draft
The OECD has published comments received in respect of the revised discussion draft on proposed changes to Article 5 (permanent establishment) of the OECD Model Tax Convention. The revised discussion draft was issued on 19 October 2012 and
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