Mexico: Mining royalty plan
A proposal to levy a new royalty tax on mining profits in Mexico, the world’s largest producer of silver, passed a congressional committee on 16 April 2013. The proposal would also increase penalties for mining concessions that have not been
See MoreUK: HMRC issues revised GAAR guidance
HMRC’s latest guidance on the application of the General Anti-Abuse Rule (GAAR) was approved by the GAAR Advisory Panel on 15 April 2013. This guidance summarizes what the GAAR is intended to achieve and how it operates to arrive at this
See MoreUK: supplementary report by the Global Forum’s Peer Review Group
A supplementary report has been issued further to the combined Phase 1-2 report issued by the OECD’s Global Forum on Transparency and Exchange of Information for Tax Purposes in September 2011. Since that date the UK has sent a follow up report to
See MoreIndia and Malta have signed a new Double Taxation Avoidance Agreement
India and Malta have signed a new Double Taxation Avoidance Agreement (DTAA) on April 8 2013. The provisions of the treaty generally follow the provisions of the OECD Model but the definition of a permanent establishment includes a building site or
See MoreTreaty between Cyprus and Finland enters into force
On 28 April 2013, the double tax agreement that was signed on 15 October 2012 between Cyprus and Finland will enter into force. The treaty generally follows the provisions of the OECD Model. Under the treaty the maximum withholding tax rate on
See MoreSouth Africa: Tax measures included in 2013 budget
Certain tax proposals presented on 27 February 2013 in South Africa’s annual budget are summarized below: There were no tax increases but there was a substantial increase in fuel levies of 23 cents from April 2013. There was no specific mention of
See MoreOECD: Global Forum moves to Phase 2 peer reviews
The OECD’s “Global Forum on transparency and information exchange for tax purposes” has a three year mandate to ensure the implementation of tax transparency standards by conducting “peer reviews” of its member countries and of other
See MoreJapan: 2013 tax reform bill has been passed
Japan’s 2013 tax reform bill passed on 29 March 2013 and the key changes are related to corporate taxation. They include the introduction of a tax credit for increased salaries paid to employees; the introduction of a tax credit / special
See MoreIndia: Tax Court rules on selection of comparables
In determining transfer prices between a taxpayer and related parties one of the permitted methods is the transactional net margin method (TNMM). This compares profit margins to an appropriate base such as sales, assets or costs realized from a
See MoreEU: Advocate General decides in favour of HMRC
The Advocate General has issued an opinion in a case referred to the European Court of Justice (ECJ) by the Danish High Court. The point at issue is whether the scope of Article 1(1) Regulation (EC) No 44/2001 includes an action brought by a State
See MoreArgentina –Modifications to the transfer pricing regulations through General Resolution N° 3,476
The Argentine Federal Tax Authorities issued General Resolution N° 3,476 on 10 April 2013. The Resolution has revised the transfer pricing compliance rules and introduced modifications to the current Transfer Pricing regulations. General Resolution
See MoreAfrican Tax Administration Forum discusses improved revenue administration
Leaders of revenue authorities from twelve African countries held a seminar in South Africa on 10–12 April 2013 to discuss issues surrounding Board governance of revenue authorities. The meeting was organized by the African Tax Administration
See MoreTransfer Pricing Brief: March 2013
Australia OECD Guidelines, the new transfer pricing rules require the provisions of the legislation to be interpreted so as to achieve the most consistency with the OECD Guidelines. Taxation Laws Amendment (Countering Tax Avoidance and
See MoreUS: Report on advance pricing agreements
The US report on advance pricing agreements issued on 25 March 2013 covers the activities of the program in 2012. At the beginning of 2012 the APA program was merged with the office of the competent authority (USCA) that is responsible for the
See MoreTaiwan: Pilot free trade zones to be established
Taiwan has revealed that pilot free trade zones are to be established to liberalize the island’s economy and upgrade the industrial structure. The Council for Economic Planning and Development (CEPD) aims to attract high value-added industries
See MoreOECD publishes mutual agreement procedure statistics for 2011
The OECD has made available the statistics for 2011 in respect of the mutual agreement procedure (MAP) in its member countries. The statistics were provided to the OECD by member countries and by Argentina and South Africa which are not currently
See MoreItaly: Report on international standard rulings
The tax authorities in Italy have issued a second International Standard Ruling Report. This provides statistics on the tax ruling system. Any enterprise that has international activities may apply for the process known as an international tax
See MoreGreece: Extension of Deadline for submission of certain tax returns
The deadline for submission of the tax returns for taxpayers falling into the scope of article 4 of paragraph 2 of the Income Tax Code has been extended until 31 May 2013, by the Ministry of Finance and all the tax returns are to be submitted solely
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