India: High Court decision that “royalty” income received under a contract prior to 1 April 1976 is exempt from tax
The High Court (HC) of Mumbai issued its decision on 8 August 2014, in the case of CIT v. Montedison S.p.A. of Italy (ITR 202 of 1993) that "royalty" income arising from contracts for supply of technical know-how prior to 1 April 1976 was exempt
See MoreIndia: Update on GST and management service fees
The Union Cabinet approved the Constitutional Amendment Bill on Goods and Services Tax (GST) on 17 December 2014 and this can be passed to parliament for consideration. The clearance of the Bill by the Cabinet was achieved by a compromise. It was
See MoreEgypt: Plans for VAT reform contribute to credit upgrade
Currently Egypt operates a simple 10% sales tax system. This tax is currently applied to only a relatively small range of products, and this means that the tax revenue for the government from this tax is uncertain, There is limited scope for
See MoreFrance: Parliament approves the Finance Bill for 2015
The French Parliament approved the Finance Bill for 2015 and the Second Amended Finance Bill for 2014 On 18 December 2014. The Finance Bill for 2015 provides that for tax audits initiated from 1 January 2015 penalties for inadequate documentation
See MoreAustralia: Practice Statement PS LA 2014/2 released by the Australian Taxation Office
The Australian Taxation Office (ATO) released guidance on what the ATO expects taxpayers to prepare in order to comply with the transfer pricing laws and manage related risks on 17 December 2014. According to guidance 25% penalty applies and
See MoreBrazil & Norway: Protocol to DTA ratified by Norway
The protocol to Income and Capital Tax Treaty (1980) between Brazil and Norway has signed on 20 February 2014 and it has been ratified by Norway. Further details will be reported when they are
See MoreNorway & Bulgaria: DTA ratified by Norway
Norway has ratified the Bulgaria - Norway Income Tax Treaty of 2014 on 4 December 2014. The new treaty will replace the Bulgaria - Norway Income and Capital Tax Treaty (1988) as soon as it enters into force and is effective in both
See MoreSouth Africa: SARS Issues Revised Capital Gains Tax Guide
The South African Revenue Service (SARS) has issued a revised version of its Comprehensive Guide to Capital Gains Tax (CGT). This update includes various changes since the guide was last published in 2011. As before the guide looks at what should be
See MoreItaly: approves fiscal budget for 2015
Italy has approved 2015 fiscal budget with deficit. The budget bill was passed by both houses of parliament when the Chamber of Deputies approved the budget on December 22. Budget implication on Tax & VAT: The Budget includes a cut in the
See MoreBulgaria: Key changes to the tax and social security legislation for 2015
The amendments to the VAT law was released in the State Gazette on 19th December 2014. The National Revenue Agency (NRA) introduced a new electronic services. This is a new opportunity declaring for both corporate and personal taxpayers. It allows
See MoreItaly & Mexico: Amended protocol to DTA approved by Italian Parliament
The Italian Parliament has approved the amended protocol to the Italy - Mexico Income Tax Treaty of 1991 on 18 December 2014 and it was signed on 23 June 2011. Further details will reported
See MoreIndonesia temporarily bans overseas travel by key tax debtors
The Ministry of Finance of Indonesia has banned overseas travel of key tax debtors with total debt amount of IDR3.32 trillion (USD268m) for a temporary period of six months. This step was taken to ensure effective tax administration and compliance.
See MoreDTA between Estonia & Luxembourg approved by Estonia
Estonia approved the Income and Capital Tax Treaty with Luxembourg on 8 December 2014. Once in force and effective, the new treaty will replace the tax treaty between Estonia and Luxembourg signed in 2006. Estonia and Luxembourg signed this new
See MoreChina issues Circular Caishui [2014] No. 59 to extend the current preferential corporate income tax treatment
China’s Ministry of Finance, the State Administration of Taxation, Ministry of Commerce, Ministry of Science and Technology and National Development and Reform Commission jointly issued Circular Cai Shui no 59 On 8 October 2014, has extended the
See MoreKorea signs new Double Taxation Agreement (DTA) with Brunei
The Republic of Korea signed a double taxation agreement (DTA) with Brunei on December 9, 2014. The appropriate legal ratification procedures will need to be completed before the agreement enters into
See MoreAustralia: Taxation Ruling 2014/8 introduces by the Australian Taxation Office (ATO)
Taxation Ruling 2014/8 gives outlines on what needs to be included in the documentation if the taxpayer is to meet the standard of a "reasonably arguable position" and avoid penalties, and sets out five key questions for preparation of
See MoreKorea: Unilateral APA program introduced
A simplified APA (Advance Pricing Agreement) program is to be introduced from 2015 for the conclusion of unilateral APAs by manufacturers, wholesalers, retailers or service providers with revenue under KRW 50 billion. Applicants will be able to
See MoreUS & Mexico finalize agreement on sugar import investigations
The U.S. Department of Commerce announced on December 19, 2014 that it had finalized agreements with the Government of Mexico and Mexican sugar exporters to suspend antidumping (AD) and countervailing duty (CVD) investigations on imports of sugar.
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