Posts by admin

China: Taxable presence of foreign entity’s seconded workers

May 16, 2013

Recently a guidance concerning when the cross-border secondment of expatriate workers by foreign enterprises into China may give rise to...

Brazil: Expands Threshold for Companies for presumed Profit Method

May 16, 2013

The profit method is one of four calculation regimes that may be applied by some companies for the computation of...

Australia: Amends Transfer Pricing Regulations

May 16, 2013

Australia has introduced the Tax Laws Amendment (Countering Tax Avoidance and Multinational Profit Shifting) Bill 2013 (“the Bill”) in the...

OECD Working Paper looks at distortive effects of Swiss tax system

May 8, 2013

A Working Paper written by Andrés Fuentes and published by the OECD looks at features of the Swiss tax system...

Hong Kong: Double tax agreement with Guernsey

May 8, 2013

The Hong Kong Special Administrative Region (SAR) of China signed a double tax agreement with Guernsey on 22 April 2013....

Ukraine: New transfer pricing law

May 8, 2013

A transfer pricing Bill to amend the legislation with regard to transfer pricing and introduce best practice was registered with...

Germany: Amendments to the taxation of portfolio dividends

May 8, 2013

A new law in respect of dividend taxation was published in the Federal Gazette on 21 March 2013. This law...

Austria:Corporate tax guidelines limit interest deductions

May 8, 2013

The Austrian Ministry of Finance published revised corporate income tax guidelines in March 2013, to tightening the rules with respect...

France-Modification to capital gains tax regime

May 8, 2013

The President of France announced on 29 April 2013 that the tax regime on capital gains is to be modified....

Brazil: Tax subtraction from donations and sponsorships

May 8, 2013

Decree No. 7,988/2013 was published in the Official Gazette of 18 April 2013 and in force as of that date....

Colombia: Proposed Regulations for Bank Debit Tax

May 8, 2013

The Colombian Government is currently preparing a Decree, which will regulate the provisions of bank debit tax. This bank debit...

UK overseas territories agree to exchange tax information

May 8, 2013

A number of UK overseas territories and crown dependencies have agreed to exchange information on tax matters with the UK...

Russia: VAT treatment of agency services in connection with alienation of ERUs

May 8, 2013

The Russian Ministry of Finance has noted that the VAT treatment of services generally depends on the place of their...

OECD releases draft handbook on transfer pricing risk assessment

May 8, 2013

The OECD has released for comment a draft handbook in respect of transfer pricing risk assessment. This is intended to...

ECJ: Decision on the inclusion of non-taxable persons in UK VAT groups

May 8, 2013

The European Court of Justice (ECJ) has issued a decision in respect of a case brought by the European Commission...

Transfer Pricing Brief: April 2013

May 8, 2013

Argentina Resolución General N° 3476 introduced new Form F4501, for filing the transfer pricing documentation report. Finland Main corporate income...

UK: HMRC announces widespread compliance with real time information

April 29, 2013

Most UK employers are now required to report their information on wages and deductions under the Pay as you Earn...

Treaty between Ireland and Ukraine signed

April 29, 2013

Ireland and Ukraine signed a Double Tax Agreement on 19 April 2013. This DTA represents an important step in boosting...