Cyprus and Ukraine finalize the procedures to bring new treaty into force

31 October, 2013

The Inland Revenue Department of the Ministry of Finance of Cyprus issued Circular No. 2013/16 on 23 September 2013, expressing that Cyprus and Ukraine have both completed all the procedures required to bring into force the new Double Tax Treaty

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Croatia: Constitutional Court decision

31 October, 2013

The Constitutional Court gave its final decision and repealed article 16(3) of the Law on the amendments to the individual income tax law on 18 September 2013. This article retroactively enforced taxation on income from dividends and participation

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Colombia: Low-Tax Jurisdictions

31 October, 2013

Decree 2193 issued on 7 October 2013 and applicable for income tax purposes as from 1 January 2014, establishes the list of countries and territories that are considered low-tax jurisdictions. For a 1-year term, certain jurisdictions are not

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China: Draft regulations relating labour dispatch

30 October, 2013

Recently, the government of China issued draft regulations relating to provisions of Labour Dispatch. Labour dispatch arrangements  are supplementary arrangements for provision of labour and can only apply in respect of temporary positions of six

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Canada: Draft proposals on character conversion transactions

30 October, 2013

Canada’s Finance Department has published draft legislative proposals for a number of the measures on September 13, 2013 that were first introduced on 21 March 21, 2013 as part of the 2013 federal budget. By the draft proposals derivative

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Canada: Quarterly formal interest rate due to include deemed interest income

30 October, 2013

The Revenue Agency (CRA) of Canada ensured that the quarterly prescribed interest rate used to determine the deemed interest income inclusion from a "pertinent loan or indebtedness" will be 5.02% for the fourth quarter of 2013 - i.e. October 1, 2013

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Canada – Eligibility of certain retirement payments for pension income splitting

30 October, 2013

The Revenue Agency (CRA) of Canada has issued a technical interpretation addressing amounts received from “retirement compensation arrangements” eligible for pension income splitting, effective for tax years 2013 and later. Pension income

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Belgium: Transition regime related to VAT

30 October, 2013

A transition regime in relation to VAT is being extended by the Belgian authorities during 2014. The regime permits taxpayer an opportunity to apply new rules for deciding the point in time when VAT is chargeable on invoices issued in advance of

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Australia may limit employment-related tax benefits

30 October, 2013

Australia has made a decisive step towards imposing restrictions on certain employment-related tax benefits which may include reforms in fringe benefits tax (FBT) and superannuation provisions. The new measures would adjust the caps outlining

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Australia: Documentation of R&D activities

30 October, 2013

As like other nations, Australia gives tax relief to companies taking part in research and development activities. However companies need to hold satisfactory documentation to show that their activities fall inside the meaning of these activities

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Australia: Draft Bill to repeal carbon tax

30 October, 2013

The Australian Prime Minister and Environment Minister on 15 October 2013 announce that the government has released draft legislation to repeal the carbon tax for public consultation. As per the government, the first enactment they will table in

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Argentina -Tax Incentives Plan for software Industry

30 October, 2013

The Argentine government issued a decree on 16 September 2013 to promote the software industry. The decree will allow tax incentives to individuals and legal entities whose core activities are in the software sector and is anticipated to promote the

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Transfer Pricing Brief: September 2013

24 October, 2013

Brazil Under Ordinance 427/2013 where the taxpayer is the lending party a spread of 2.5% is to be added to the minimum interest rate. Ordinance 427/2013 sets a maximum spread of 3.5% for purposes of calculating the tax deduction for

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WTO Public Forum discusses trade facilitation

23 October, 2013

The WTO Public Forum was held on 1 to 3 October 2013. The third day of the meeting was devoted to discussion of issues that were relevant to the OPEC summit in Bali. These issues included trade facilitation as well as economic development issues and

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US: IRS Corrects Final Regulations on FATCA Reporting and Withholding

22 October, 2013

In Announcement 2013-14, the Internal Revenue Service (IRS) corrected final regulations (T.D.9610) regarding information reporting by foreign financial institutions (FFIs) with respect to U.S. accounts and withholding on payments to FFIs and other

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Treaty between Senegal and South Africa signed

22 October, 2013

Senegal and South Africa signed a tax treaty, in Senegal. No further details of the treaty are currently available. South Africa has signed two other agreements with Senegal – a memorandum of understanding on agriculture, and a co-operation

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Treaty between Estonia and Morocco signed

22 October, 2013

Estonia and Morocco signed a tax treaty on 25 September 2013 in New York. It was signed during a visit by the ministers of Foreign Affairs to the 68th session of the General Assembly of the United Nations.  No further details are currently

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Kazakhstan-Luxembourg DTT approved by Kazakhstan

22 October, 2013

Kazakhstan’s Lower House of Parliament has approved the Kazakhstan – Luxembourg Income and Capital Tax Treaty (2008) on September 25, 2013 which was signed on June 26, 2008, and the amended protocol was signed on May 3, 2012. The treaty and

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