Israel: Budget for the FY 2013-2014
Israeli cabinet has approved the Budget for fiscal year 2013-2014. The VAT rate has been raised to 18% as from June 1, 2013 (previously 17%). The corporate income tax rate has been increased to 26% from 25% and the personal income tax rate will be
See MoreIndia: CBDT has withdrawn the guideline of profit-split method for transfer-pricing transactions, and amends the circular on contract R&D
The Central Board of Direct Taxes (CBDT) withdrew Circular No. 2/2013 on June 2013as it gives the impression that the profit split method is the preferred method in cases involving unique intangibles or in multiple interrelated international
See MoreHong Kong: Tax reduction bill
The Inland Revenue (Amendment) (No. 2) Bill 2013 was passed on 26 June 2013 by the Hong Kong Legislative Assembly to implement the tax reduction measures proposed in the 2013-14 Budget. The concessionary revenue measures highlight the following
See MoreECJ gives a preliminary ruling on the place of supply of storage services
RR Donnelly Global Turnkey Solutions Poland supplied services related to the storage of goods to companies located inside and outside the EU. The Polish government considered that the services were liable to VAT in Poland because they were services
See MoreUK: Consultation on community amateur sports clubs
The UK government has published a consultation document in respect of tax relief given to community amateur sports clubs. The current relief gives some tax relief that is similar to the relief given to charities, but policy is being reconsidered in
See MoreSwitzerland: Plans to raise VAT for Pension Fund
Switzerland has declared plans for increase two percent value-added tax (VAT) rate, which will be started on a transitional basis beginning in 2020. On June 21, 2013 the Swiss Government announced the tentative proposals include an increase in the
See MoreOECD: Treatment of termination payments in tax treaties
A discussion document on the treatment of termination payments in tax treaties was issued by the OECD on 25 June 2013. The document discusses various categories of payment made to employees on or after the termination of their employment and
See MoreOECD report on automatic information exchange
Following an emphasis on information exchange on request and the commencement of peer reviews by the OECD Global Forum on Tax Transparency and Information Exchange, the exchange of tax information is being taken to a further level with the
See MoreDocumentation Considered in Malaysia’s First Transfer Pricing Case
The Special Commissioners of Income Tax in Malaysia delivered a landmark decision on February 2013 in the favour of the taxpayer in the first transfer pricing litigation in Malaysia. The case concerned assessments on a shipping and logistics
See MoreIndonesia: New Regulation on Transfer Pricing Audits
Regulation PER 22/PJ/2013 has been published by the Indonesia’s Directorate General of Taxation (DGT) on 30 May 2013 to provide guidelines for audits of taxpayers with related-party relationships and repealed the regulation KEP-01/PJ 07/1993
See MoreIndia: CUP method for benchmarking service contracts
In a recent decision of Income Tax Appellate Tribunal (“ITAT”) it was held that for benchmarking service contracts when comparable data for these contracts is available the comparable uncontrolled price (CUP) method is the most suitable method.
See MoreHungary: New Decree on Transfer Pricing Documentation Rules
The Hungary’s Ministry of Finance has issued Decree 20/2013 on 18 June 2013. The decree clarified the transfer pricing documentation obligations of Hungary. The Decree 20/2013 is designed to decrease the taxpayers’ administrative burden and to
See MoreFrance: report on tax evasion, transfer pricing
The French Minister of Economy and Finance published an official report on transfer pricing legislation on 5 June 2013. The report concludes that France’s transfer pricing rules are out of step with international counterparts. The French General
See MoreECJ rules on relevance of contractual terms in VAT supply
The European Court of Justice (ECJ) has reached a decision in the case of HMRC v Paul Newey t/a Ocean Finance (C-653/11). This case concerned the relevance of contractual terms to the identification of the supplier and recipient of services for the
See MoreECJ: Advocate General issues opinion on VAT and educational services
A question was referred to the ECJ by the Supreme Court of Poland in respect of VAT on educational services. The Advocate General has now issued an opinion on the case, which is however not binding on the ECJ which will issue its decision at a later
See MoreCzech Republic: New Decree on Low Value Adding Services
The General Financial Directorate (D-10) has issued the new Decree related to Low Value Adding Services took into effect on January 1, 2013 and it will relief qualifying taxpayers from preparation of full-phase transfer pricing documentation and
See MoreUK: consultation on allowing the transfer of savings in child trust funds to junior ISAs
The UK government has published a consultation document in respect of allowing the transfer of savings from a Child Trust Fund to a junior Individual Savings Account (Junior ISA). Child trust funds were originally introduced in 2004 with the
See MoreUK: Double tax agreement with the Netherlands on bank taxes
The UK and the Netherlands signed a double tax convention on 12 June 2013 in respect of bank taxes. The taxes covered by the Convention are the UK bank levy under Schedule 19 FA 2011 and the tax charged under the Netherlands law on bank tax. The
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