India: Requirements For Transfer pricing’s “deemed international transaction”

May 22, 2013

India’s transfer pricing rules are designed to prevent the use of transfer prices between related enterprises to shift profits away from India to a lower tax jurisdiction. The rules are therefore generally concerned with international transactions

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Canada – Tax-related interest rates for 2014

May 22, 2013

It was announced by the Canada Revenue Agency (CRA) that tax-related interest rates for taxable credits and for tax overpayment and underpayments for the third quarter of 2013 (July 1- September 30) will remain unchanged for this year and the rates

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Australia: Draft taxation determination on non-deductibility of support payments

May 22, 2013

The Australian Taxation Office (ATO) has discharged a draft Taxation Determination TD 2013/D3. The draft determination is appropriate to arrangements between a parent entity and its subsidiary entity. According to the draft TD 2013/D3, support

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United States: IRS publishes quarterly list of individuals who have expatriated

May 16, 2013

The US Internal Revenue Service (IRS) 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 required under section 6039G

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UK: HMRC analyses data on tax schemes

May 16, 2013

The UK tax authority HMRC has received information indicating the extensive use of tax schemes to hide assets in overseas locations and it is working with the governments of Australia and the US to analyze a large amount of data. The data indicates

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Norway : Tax Cut Plan for 2014

May 16, 2013

The Norwegian Prime Minister announced plans on 5 May 2013 for a modest tax cut for mainland businesses and for increasing taxes on oil companies and multinationals. This plan includes a reduction in the general corporate tax to 27% from 28%

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Canada: Reforming Temporary Foreign Worker program

May 16, 2013

Currently, Canadians have raised concerns about the Temporary Foreign Worker Program. A review of the Temporary Foreign Worker Program has been incorporated in the Economic Action Plan 2013 and legislation has been enacted to change the rules. It

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Australia: Proposal to amend GAAR

May 16, 2013

The Australian government on 13th February 2013 introduced Tax Laws Amendment Bill 2013. According to Tax Laws Amendment Bill 2013, companies will have to ensure that the commercial and other factors motivating a decision are properly documented.

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Ukraine: Draft Law amendments regarding the formation of a tax group

May 16, 2013

Draft Law No. 2737 introduces amendments regarding the formation of a tax group. On 5 April 2013, amendments to the Tax Code were sent to be approved by the parliament. The legislation will allow companies in Ukraine to form a consolidated tax group

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Russia: Offering New Transfer Pricing Deadlines

May 16, 2013

The Russian government has sent Draft Law No. 79859-6, which offers to set new transfer pricing deadlines for taxpayers for the second reading to the lower house of the Russian parliament. These changes may impact international businesses operating

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China: Taxable presence of foreign entity’s seconded workers

May 16, 2013

Recently a guidance concerning when the cross-border secondment of expatriate workers by foreign enterprises into China may give rise to a taxable presence in China is issued by the China’s State Administration of Taxation. Factors taken into

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Brazil: Expands Threshold for Companies for presumed Profit Method

May 16, 2013

The profit method is one of four calculation regimes that may be applied by some companies for the computation of profits for Brazil’s corporate income tax. This is a simplified regime that enables a company to pay tax based on a percentage of its

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Australia: Amends Transfer Pricing Regulations

May 16, 2013

Australia has introduced the Tax Laws Amendment (Countering Tax Avoidance and Multinational Profit Shifting) Bill 2013 (“the Bill”) in the House of Representatives for approval. The new transfer pricing regulations will significantly bolster the

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OECD Working Paper looks at distortive effects of Swiss tax system

May 08, 2013

A Working Paper written by Andrés Fuentes and published by the OECD looks at features of the Swiss tax system and examines the extent to which certain aspects of the system may have a distorting effect on the Swiss economy. Generally Switzerland

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Hong Kong: Double tax agreement with Guernsey

May 08, 2013

The Hong Kong Special Administrative Region (SAR) of China signed a double tax agreement with Guernsey on 22 April 2013. The agreement provides for the taxation of business profits of a permanent establishment in the other contracting state and

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Ukraine: New transfer pricing law

May 08, 2013

A transfer pricing Bill to amend the legislation with regard to transfer pricing and introduce best practice was registered with parliament on 12 March 2013. The Tax and Customs Committee of parliament has confirmed that the Transfer Pricing Bill

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Germany: Amendments to the taxation of portfolio dividends

May 08, 2013

A new law in respect of dividend taxation was published in the Federal Gazette on 21 March 2013. This law has been introduced following a decision of the European Court of Justice in 20 October 2011 which required a review of the taxation of

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Austria:Corporate tax guidelines limit interest deductions

May 08, 2013

The Austrian Ministry of Finance published revised corporate income tax guidelines in March 2013, to tightening the rules with respect to interest deductions in connection with “debt push-down models” and concerning tax loss carry forwards

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