OECD Holds Public Meeting on the Prevention of Treaty Abuse
On 22 January 2015 the OECD held a public consultation meeting to discuss the base erosion and profit shifting (BEPS) action 6 on the prevention of tax treaty abuse. The issue as presented in the OECD’s discussion draft on this issue and the
See MoreOECD holds public consultation on preventing the artificial avoidance of PE status
On 21 January 2015 the OECD held a public consultation on the artificial avoidance of permanent establishment (PE) status. This is action 7 of the action plan on base erosion and profit shifting (BEPS). The OECD Model tax treaty permits the host
See MoreTaiwan: Individual Income Tax Modified
The Legislative Congress in Taiwan passed an amendment to article 15 of the Income Tax Act on 6 January 2015 which allows partners to calculate their income and subject themselves to individual income tax separately. The new regime retrospectively
See MoreCanada: Customs Notice permits import duty refund claims on transfer pricing adjustments
Basically, Customs Notices are issued to inform clients about proposed changes to customs procedures. Customs Notice N-15-001 has been published by the Canada Border Services Agency (CBSA) for deleting an obstacle to file import duty refund claims.
See MoreHong Kong: Government Renews Anti-Money Laundering Guidelines
Hong Kong has gazetted an anti-money laundering amendment notice that will allow its financial institutions to continue to delegate customer due diligence (CDD) functions. The Anti-Money Laundering and Counter-Terrorist Financing (Financial
See MoreFrance and Austria Seek To Launch FTT In 2016
France and Austria sought to break deadlocked talks with nine other European countries for a financial transaction tax, by proposing a broader financial transaction tax with a lower rate, in an attempt to push forward delayed plans for a European
See MoreSpain: Government Announces New Country-by-Country Reporting Obligations for MNEs
The Spanish government on 20 January 2015 announced that it will issue regulations, expected to be adopted in the first half of 2015, that will require country-by-country reporting by multinationals. The new regulations would enter into force on 1
See MoreWTO Launches Process to Agree Doha Programme
A meeting was held on 21 January 2015 at which the Director General of the World Trade Organization (WTO) began a new consultation process aimed at agreeing on a programme of work to discuss the remaining Doha Development Agenda issues by July 2015.
See MoreOECD Publishes Comments on Transfer Pricing for Low Value Adding Intragroup Services
Intragroup services would include centralized services such as administration, accounting, legal, computer, staff matters and training, which are all considered to be intragroup services. Arm’s length charge Having determined that the services
See MoreAfrican Tax Research Network to Hold its First Annual Congress
The first Annual Congress of the African Tax Research Network (ATRN) is to take place in Zimbabwe on 2 to 4 September 2015. The ATRN has been established to continue dialogue, research and collaboration on tax matters between tax administrators, tax
See MoreSlovak Republic-Guernsey TIEA enters into force
The Tax Information Exchange Agreement (TIEA) between Guernsey and Slovakia has signed and will come into force on 26th January
See MoreFrance: National Assembly Approves The Treaty With Andorra
The French National Assembly approved the income tax treaty with Andorra on 20 January 2015. Further details of the treaty will be reported
See MoreCanada: Exemption limit on capital gains for 2015
The Economic Action Plan 2013 offers to raise the Lifetime Capital Gains Exemption (LCGE) to CAD800,000 from CAD750,000 for the recognition of the importance of small business owners, farmers and fishermen. With indexing, the LCGE limit for the year
See MoreHong Kong: Government Intends To Extend Offshore Fund Exemption Regime
New rules in Hong Kong are being planned to exempt offshore private equity funds from tax in Hong Kong with respect to investments made outside of Hong Kong. The proposed changes were initially announced by the Financial Secretary in his 2013/14
See MoreThe United Kingdom and Croatia sign a Double Taxation Agreement (DTA) on January 15, 2015
The United Kingdom and Croatia have signed a Double Taxation Agreement (DTA) on January 15, 2015. The aim of this agreement is to avoidance of double taxation and prevention of fiscal
See MoreFrance: Increases Transfer Pricing Documentation Penalties
France’s 2015 Finance Bill, enacted on December 29, 2014, increased the penalties applicable in cases of failure to comply with the French transfer pricing documentation rules. The newly defined penalty for a failure to produce transfer pricing
See MoreNigeria: The Budget Proposal 2015 presents
The Coordinating Minister for Economy and Finance in Nigeria has presented the Budget proposal for the year 2015 to the National Assembly on 17th December 2014. The appropriation bill was talked in the second reading of the Senate on 15th January
See MoreVietnam – Publishes Guidance on Corporate Income Tax Incentives
Vietnam publishes guidance on corporate income tax incentives for enterprises that rearrange or with respect to incentives granted on a “location basis.” Under December 2014 guidance, if an enterprise is currently enjoying the benefits of a
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