China: Taxable presence of foreign entity’s seconded workers
Recently a guidance concerning when the cross-border secondment of expatriate workers by foreign enterprises into China may give rise to a taxable presence in China is issued by the China’s State Administration of Taxation. Factors taken into
See MoreBrazil: Expands Threshold for Companies for presumed Profit Method
The profit method is one of four calculation regimes that may be applied by some companies for the computation of profits for Brazil’s corporate income tax. This is a simplified regime that enables a company to pay tax based on a percentage of its
See MoreAustralia: Amends Transfer Pricing Regulations
Australia has introduced the Tax Laws Amendment (Countering Tax Avoidance and Multinational Profit Shifting) Bill 2013 (“the Bill”) in the House of Representatives for approval. The new transfer pricing regulations will significantly bolster the
See MoreOECD Working Paper looks at distortive effects of Swiss tax system
A Working Paper written by Andrés Fuentes and published by the OECD looks at features of the Swiss tax system and examines the extent to which certain aspects of the system may have a distorting effect on the Swiss economy. Generally Switzerland
See MoreHong Kong: Double tax agreement with Guernsey
The Hong Kong Special Administrative Region (SAR) of China signed a double tax agreement with Guernsey on 22 April 2013. The agreement provides for the taxation of business profits of a permanent establishment in the other contracting state and
See MoreUkraine: New transfer pricing law
A transfer pricing Bill to amend the legislation with regard to transfer pricing and introduce best practice was registered with parliament on 12 March 2013. The Tax and Customs Committee of parliament has confirmed that the Transfer Pricing Bill
See MoreGermany: Amendments to the taxation of portfolio dividends
A new law in respect of dividend taxation was published in the Federal Gazette on 21 March 2013. This law has been introduced following a decision of the European Court of Justice in 20 October 2011 which required a review of the taxation of
See MoreAustria:Corporate tax guidelines limit interest deductions
The Austrian Ministry of Finance published revised corporate income tax guidelines in March 2013, to tightening the rules with respect to interest deductions in connection with “debt push-down models” and concerning tax loss carry forwards
See MoreFrance-Modification to capital gains tax regime
The President of France announced on 29 April 2013 that the tax regime on capital gains is to be modified. To encourage entrepreneurship the government will simplify the different existing regimes. Since 1 January 2013, occasional capital gains on
See MoreBrazil: Tax subtraction from donations and sponsorships
Decree No. 7,988/2013 was published in the Official Gazette of 18 April 2013 and in force as of that date. Individuals and legal entities under the actual profit regime can deduct sponsorships and donations made to the National Program for
See MoreColombia: Proposed Regulations for Bank Debit Tax
The Colombian Government is currently preparing a Decree, which will regulate the provisions of bank debit tax. This bank debit tax was introduced by Law 1607 of 2012. This proposed Decree will provide for exemptions and the refund of the bank debit
See MoreUK overseas territories agree to exchange tax information
A number of UK overseas territories and crown dependencies have agreed to exchange information on tax matters with the UK and other major European countries. Anguilla, Bermuda, the British Virgin Islands (BVI), Montserrat and the Turks and Caicos
See MoreRussia: VAT treatment of agency services in connection with alienation of ERUs
The Russian Ministry of Finance has noted that the VAT treatment of services generally depends on the place of their supply. Recently they issued Letter No. 03-07-08/4775 on February 20, 2013 regarding the VAT treatment of agency services supplied
See MoreOECD releases draft handbook on transfer pricing risk assessment
The OECD has released for comment a draft handbook in respect of transfer pricing risk assessment. This is intended to be a practical resource for tax administrations to follow in developing a risk assessment approach to transfer pricing issues.
See MoreECJ: Decision on the inclusion of non-taxable persons in UK VAT groups
The European Court of Justice (ECJ) has issued a decision in respect of a case brought by the European Commission concerning the provision for VAT groups in the UK. The UK argued in support of its position that non-taxable persons could be included
See MoreTransfer Pricing Brief: April 2013
Argentina Resolución General N° 3476 introduced new Form F4501, for filing the transfer pricing documentation report. Finland Main corporate income tax rate has been reduced to 20%. India Circular 2/2013 clarifies that the profit split
See MoreUK: HMRC announces widespread compliance with real time information
Most UK employers are now required to report their information on wages and deductions under the Pay as you Earn (PAYE) scheme in real time. The UK tax authority HMRC announced last week that more than 680,000 employers have begun reporting PAYE in
See MoreTreaty between Ireland and Ukraine signed
Ireland and Ukraine signed a Double Tax Agreement on 19 April 2013. This DTA represents an important step in boosting trade relations between Ireland and Ukraine. The treaty will enter into force when the relevant ratification procedures have been
See More