South Africa: Tax consequences of debt reduction transactions
South Africa’s Taxation Laws Amendment Act, 2012, includes provisions that revise the tax treatment of debt reduction transactions entered into on or after 1 January 2013. Since the objective of the new tax reduction rules is to make it easier
See MoreSouth Korea- Planning of Acquisition Tax Cuts
The South Korean Government announced on 30 August 2013 that the tax rates on home purchases would be decreased in order to encourage a rise in transaction numbers. An exemption from property acquisition tax was granted in April 2013, but the
See MoreSwitzerland agrees plans for settling US Tax conflict
The Federal Council of Switzerland has agreed to plans for reconciling the Confederation’s tax conflict with the US. The Council of the Federal Finance Department has established a mutual statement designed to draw a line under past dispute over
See MoreUK introduces employee shareholder status
From 1 September 2013 employee shareholder status has been introduced in the UK. This allows an employer to enter into a contract with an employee whereby some employment rights are given up by the employee in exchange for shares in the employer’s
See MoreUK: alternative dispute resolution is now available to SMEs and individuals
From 2 September 2013 alternative dispute resolution (ADR) is now available to small and medium enterprises (SMEs) and individuals. If a taxpayer that is in dispute with HMRC asks for ADR a facilitator will be appointed from within HMRC. The
See MoreUK: Corporation tax statistics
On 30 August 2013 HMRC released the latest corporation tax statistics. The publication shows the statistics for corporation tax receipts for 2012/13 and some revised figures in relation to corporation tax liabilities of previous years. Also shown
See MoreTransfer Pricing Brief: August 2013
Indonesia Certain small and medium enterprises may be taxed on the basis of 1% of turnover. Israel Lower rates apply to companies eligible under the Law for the Encouragement of Capital Investment. Malaysia A Transfer Pricing Audit Framework
See MoreAustralia: Effective date of new Transfer Pricing rules
The new transfer pricing rules introduced by Australia are effective for years starting on or after 1st July 2013 and will apply to the transactions of all multinational entities operating in Australia. Before documenting their assessment forms,
See MoreBelgium: Introduction of “fairness tax” on companies
The Belgian government has introduced a “fairness tax” on companies. Due to compensation for losses or notional interest deductions, if companies dividends are paid and corporate tax is not paid, will be liable to pay this fairness tax. In an
See MoreBrazil: Guidance Issued on the Pricing of Interest Bearing Transactions
The Brazilian Ministry of Finance has issued an ordinance 427/2013, On 2 August 2013, which finally define and clarifies the interest rate spread and that was mentioned but not specified in Law 12.766/2012. Under Ordinance 427/2013 where the
See MoreCanada – Amends to foreign affiliate dumping rules proposed by the Government
The draft legislation has introduced on August 16, 2013, to make revisions to the foreign affiliate dumping (FAD) rules that were first declared as part of the 2012 federal budget and enacted on December 14, 2012 according to Bill C-45 and it would
See MoreChina signs agreement for mutual assistance in tax matters
China signed the Multilateral Convention on Mutual Administrative Assistance on 27 August 2013 in Tax Matters. The Convention provides a framework for cooperation between tax authorities to exchange tax information. The OECD and the G20 are
See MoreChina: Eligibility of software enterprises for corporate income tax incentives
To clarify the rules concerning software enterprises that are eligible for certain corporate income tax incentives, China’s State Administration of Taxation has issued guidance on the issues arising in qualifying for these incentives. According
See MoreColombia: Agreement with World Bank on Tax Matters
The World Bank signed an agreement with Colombia on August 19, 2013. This is to improve its tax collection. The agreement will be in force between August 2013 and August 2015. In order to strengthening the tax system, the World Bank will supply
See MoreCroatia amends the General Tax Law
Amendments to the General Tax Law have been published in Official Gazette No. 73/2013 and they entered into force on 26 June 2013.EU law with effect from 1 July 2013, Some EU directives have been implemented into Croatian legislation like- Mutual
See MoreCroatia: Government proposes amendments to Individual Income Tax Law
The government has proposed amendments to the Individual Income Tax Law on 25 July 2013. Following the constitutional court decision these amendments provide that dividends or participation in profits obtained after 31 December 2000, but paid out
See MoreCyprus: Tax treatment of loan write-off by a financial institution
Recently guidance with respect to the tax treatment of a loan write-off by a financial institution, for the benefit of the borrower, has been issued by the tax authority of Cyprus. According to Circular 2013/14 of 30th May 2013, a partial or
See MoreCzech Republic – Postponement of provision to implement FATCA
A package of proposals has been submitted by the Finance Ministry for making consideration by the Parliament but legislative consideration of several of the provisions has been postponed. One of the items included in the proposals, which would put
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