India: CBDT Publishes draft guidelines for determination of the POEM
The Central Board of Direct Taxes (CBDT) on 24 January 2017, has issued the guiding principles to be followed for determination of the place of effective management of a company (POEM). The concept of PoEM for deciding the residential status of a
See MoreAustria: Announces social security rates for 2017
The Social Security act of Austria has been amended and published in the Official Gazette on 18 January 2017. The amendment provides that the total social security rate is set at 14.12% for employees not earning more than EUR 425.70 per
See MoreProtocol to treaty between Armenia and Belarus enters into force
The amending protocol to a treaty between Armenia and Belarus has entered into force on 26 December 2016. It was signed on 19 May 2016 for the avoidance of double taxation and the prevention of fiscal evasion with respect to taxes on income. The
See MoreIndia: Approves amendment in modified special incentive package Scheme
On 18 January 2017, the Indian Union Cabinet has given its approval for amendment in the Modified Special Incentive Package Scheme (M-SIPS) to further incentivize investments in Electronic Sector and moving towards the goal of ‘Net Zero imports’
See MoreSlovenia publishes CbC reporting guidelines
The Slovenian Financial Administration published a new guidance on the implementation of country-by-country (CbC) reporting on 12 January 2017. The new guidelines included in Action 13 of the OECD Action Plan on Base Erosion and Profit Shifting and
See MorePakistan: Introduces an incentive scheme for industrial and trade sectors under no question on source of investment
The government has agreed on a new incentive scheme for industrial and trade sectors under which tax authorities will not question the source of investment, industry sources said on 22 January 2017. Sources in Federal Board of Revenue (FBR) also
See MoreSweden: Administrative Court rules PE exists in Sweden due to regular nature of activities
The Swedish Administrative Court of Appeal in the case of: Gothenburg (Kammarrätten i Göteborg) case number 2276-15, has found a German company to have a permanent establishment (PE) in Sweden due to its annually recurring short-term activities in
See MoreVietnam approves protocol to a treaty between India and Vietnam
On 17 January 2017, through a press release published by the Vietnamese government, Vietnam has approved the amending protocol to a treaty between India and Vietnam. The treaty (India-Vietnam) was signed on 3 September 2016 for the avoidance of
See MoreIndia: Loss making company couldn’t be excluded from comparable list if it satisfies comparability analysis
The Ahmedabad Bench of Income-tax Appellate Tribunal in case of: Erhardt+Leimer (India) Private Limited v. ACIT (ITA Nos. 3298/Ahd/2011 & 2880/Ahd/2012) held that consistent loss-making companies cannot be rejected as comparable unless the
See MoreIndia: Foreign tax credit allowed on the basis of gross receipts
The Ahmedabad Bench of the Income-tax Tribunal (the Tribunal) in the case of Elitecore Technologies Private Limited, held that the Foreign Tax Credit (FTC) is eligible on ‘income’ and not on ‘gross receipts’. However, based on unusual facts
See MoreJapan and Austria: Agreement in principle on tax arbitration
The Governments of Japan and Austria have agreed in principle to amend their double taxation avoidance agreement to further promote trade and investment between the two countries. The new agreement would enable arbitration under the mutual agreement
See MoreDTA between Japan and Latvia signed
The governments of Japan and Latvia signed their first tax treaty in Tokyo on 18 January 2017. The treaty will come into force when the two countries have ratified the provisions and notified each other of the completion of procedures. According to
See MoreProtocol to a treaty between India and Kuwait signed
The Kuwaiti Ministry of Finance on 15 January 2017, signed a protocol with India amending the agreement between the two countries to avoid double taxation on income and to prevent tax evasion. The protocol amends the types of Kuwaiti taxes in
See MoreSlovenia: Publishes advance pricing agreement rules
Details on the introduction of Advance Pricing Arrangements (APAs) are now available in the Official Gazette on 28 December 2016. Accordingly, the following rules will apply from January 2017: (i) The application of APA must be addressed to the
See MoreAustria-EU: Further details of tax changes
The Austrian Ministry of Finance on 2 January 2017, published a report on the tax changes that are applicable from 2017. In addition to the measures already described, further changes regarding 'EU measures' are summarised below: Beneficial
See MoreGermany: Announces reduction of energy tax for manufacturing companies
The Ministry of Finance issued a press release on 11 January 2017, specifying that be eligible manufacturing companies may apply a percentage of the tax cap on their 2017 electricity and energy tax due because energy consumption reduction goals were
See MorePakistan: Introduces 2% tax rebate
The federal government has approved the tax reduction proposal of 2% for Shariah-compliant listed companies through Finance Act
See MoreDominican Republic: Tax Authorities publishes new request forms for all tax-related procedures
The tax authority (DGII) of the Dominican Republic has recently published on its website, a set of new forms that taxpayers are to use for most tax-related procedures. The new forms exchange the prior letter request format used by taxpayers seeking
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