South Africa: SARS Issues Tax Ruling On Unbundling Transactions
The South African Revenue Service (SARS) has issued a draft Binding General Ruling (BGR), the interpretation of Section 46 of the Income Tax Act, which deals with unbundling transactions. A company under an unbundling transaction (the unbundling
See MoreExchange of Information Agreements (TIEAs) between South Africa and Argentina enters into force
According to media reports, the tax information exchange agreement (TIEA) signed between South Africa and Argentina entered into force on November 28, 2014. The Agreement shall apply to any identical taxes imposed after the date of signature of the
See MoreUS Imposes Preliminary Anti-Subsidy Duties On Chinese Tires
The U.S. Commerce Department has set preliminary anti-dumping duties ranging from 12.5 percent to 81.29 percent on tires imported from China. Five years ago, following a previous USW complaint, the US imposed AD and CVD tariffs on similar Chinese
See MoreIndia: Taxpayer’s use of the Resale Price Method for distribution activities Supported by the court
In the case of : CIT v. L’Oreal India Pvt. Ltd. (ITA No. 1046 of 2012 (7 November 2014), The Bombay High Court confirmed a tribunal decision that, the taxpayer’s use of the Resale Price Method (RPM) for purposes of determining the arm’s
See MoreMauritius: Guidance for implementing FATCA
The Mauritius Revenue Authority released guidance on 26 November 2014 which is intended to provide practical assistance to financial institutions, businesses, and officials dealing with the application of the FATCA regulations. Also, this guidance
See MoreOECD Releases Mutual Agreement Procedure Statistics for 2013
The OECD Model Tax Convention includes a provision for a mutual agreement procedure (MAP) in Article 25. Under this procedure the competent authorities of the two contracting states are required to endeavor to reach agreement to resolve issues that
See MoreFATCA Agreement Sign Between Barbados And United States
The Government of Barbados and the United States have signed an inter-governmental agreement (IGA), on 17 November 2014, to facilitate compliance with the US Foreign Account Tax Compliance Act (FATCA). Under the agreement, Foreign Financial
See MoreSweden: Ratifies TIEA with Hong Kong
Sweden has ratified its TIEA with Hong Kong on November 19, 2014, which was signed on 22 August
See MoreSpain Approves Comprehensive Tax Reform Plans
Spanish parliament has approved the comprehensive tax reforms plans on 24 November 2014, which will be published shortly in the Official Gazette. The legislation will enter into force from January 1, 2015 and followings changes have been taken
See MoreVenezuela: President signs off on tax increases
In order to increase and diversify government revenue, Venezuela`s President has accepted tax increases on 18th November 2014. 28 laws have been passed to incorporate an increment in the excise duty for buying luxury goods from 10% to 15%. This
See MoreCzech Republic-Kazakhstan Signs Protocol To Income and Capital Tax Treaty
The amending protocol of Income and Capital Tax Treaty (1998) between Czech Republic and Kazakhstan that was authorized on 16th October 2013 and has signed on 24th November 2014. Further details will be reported
See MoreAustria: Approves draft version of 2nd Tax Law Amendment Act 2014
The government of Austria approves a draft version of the 2nd Tax Law Amendment Act 2014 (2. Abgabenänderungsgesetz 2014) on 18 November 2014, it also submitted for parliamentary
See MoreAustralia: New Taxation Ruling TR 2014/6 introduced by the Australian Taxation Office (ATO)
Taxation Ruling TR 2014/6 gives guidance on identifying situations where the form of commercial or financial relations differs from the substance and confirms the ATO's power to disregard and reconstruct transactions that lack economic substance.
See MoreCanada: Pension contribution boundaries for 2015
The Canada Revenue Agency (CRA) has declared the 2015 contribution bounds for retirement-related and pension plans. It incorporates Money Purchase Registered Pension Plans, Registered Retirement Savings Plans, and Deferred Profit Sharing
See MoreRussia: President signs new tax monitoring law
The Russian President has signed the Federal Law No. 348-FZ on 4th November 2014 that enacts a new tax administration regime for large taxpayers in respect of the exchange of information between tax authorities and taxpayers. This tax monitoring
See MoreSlovak Republic: Law amendments regarding excise duties signs
The amendments to the law related to excise duties were signed by the President on 19th November
See MoreRussia: CFC law has been adopted by the Federal Council
The Federal Council has adopted the draft law on 19th November 2014 that initiates the CFC rules. There is no significant change in the adopted law compared to the previous draft. This law will enter into force with effect from 1st January
See MoreVenezuela: Amendments contain income tax and VAT
The president has declared the enactment of a series of laws to notice the economic development in Venezuela on 18th November 2014. These laws includes the following tax related items: Income tax reformation to raise tax collection via the
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