Nigeria introduced new TP regulations

January 06, 2013

Nigeria has announced new Transfer Pricing Regulations on October 22, 2012. This will be applicable retroactively to August 2, 2012. The TP Regulations provide that all transactions between connected parties should be at arm’s length. Taxpayers

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Mexico: Budget for 2013 has been approved

January 06, 2013

Congress has approved the Budget for 2013 and published in the Official Gazette on 13 December 2012. In new budget some changes has approved: The corporate income tax rate it will reduce to 29% as from 2014 but 4.9% income tax withholding rate will

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Income tax treaty between Portugal and Georgia

January 06, 2013

Georgia and Portugal signed an income tax treaty on 21 December

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Colombian Congress Approves Tax Reform

January 06, 2013

New Colombian tax rules have come into effect from 1 January 2013. Purpose behind this tax reform was to decrease the country’s unemployment rate and address society’s high wealth differences. The reforms have decreased the corporate income tax

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Amendments to Azerbaijani Tax Code

January 06, 2013

The Azerbaijani parliament adopted a draft law on amendments to the Tax Code on 21 December 2012, these came into effect from 1 January 2013. These changes are aimed at improving the tax system, reducing the tax burden and improving the tax culture.

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Canada: CRA issues transfer pricing memoranda

January 06, 2013

The Canada Revenue Agency (CRA) has to follow the OECD Guidelines when performing transfer pricing audits.  Two new transfer pricing memoranda (TPM-13 & TPM-14) have been issued. TPM-13 deals with referrals to the Transfer Pricing Review

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Income and Capital Tax Treaty between Saudi Arabia and Ukraine

January 03, 2013

To build tax cooperation, Saudi Arabia and Ukraine signed an Income and Capital Tax Treaty on 2 September 2011 which enters into force on 1 December 2012. The treaty will be effective from 1 January 2013. According to the treaty the default tax

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Treaty between Georgia and Slovenia signed

January 03, 2013

Georgia and Slovenia signed an Income and Capital Tax Treaty on 7 December

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Hong Kong and Canada sign DTA

January 03, 2013

An extensive double taxation agreement between the Government of Canada and the Government of the Hong Kong was signed on November 11, 2012 for the avoidance of double taxation. According to agreement, the rate of withholding for dividends paid

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DTA between Taiwan – Germany Enters Into Force

January 03, 2013

The double taxation agreement (DTA) between Taiwan and Germany entered into force on November 7, 2012.  The treaty will be applicable from January 1, 2013. This agreement covers the avoidance of double taxation of dividends and capital

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Treaty between China (People’s Rep.) and Japan applies to new Japanese taxes

January 03, 2013

The State Administration of Taxation (SAT) stated in Gong Gao No.49, that, Chinese and Japanese tax authorities have agreed after consultation that the taxes to which the China (People's Rep.) - Japan Income Tax Treaty applies include the Special

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Double Tax Agreement between Germany and Liechtenstein

January 03, 2013

Liechtenstein and Germany signed a bilateral double taxation agreement on 2011. The treaty will become effective from 1 January 2013. As per the agreement, there will be relief from withholding taxes for cross-border holdings as both countries

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Denmark: New Anti-Avoidance rule approved by parliament

January 03, 2013

The Danish Ministry of Taxation approved the Bill on 14 December 2012 relating anti-avoidance rules about withholding tax on dividends. The key points of the Bill are summarized below: Under the Danish holding company rule dividends (resident to

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The  Czech Republic and Denmark Income Tax Treaty enters into force

January 03, 2013

The Czech Republic and Denmark signed an Income Tax Agreement on 22 December 2012.The treaty will be applicable from 1 January 2013. The new treaty replaces the former Czechoslovakia – Denmark Income and Capital Tax Treaty (1982), as amended by

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