India: High Court Decision on Transfer Pricing Comparability
The High Court of Bombay issued its decision in the case of: CIT v. Garware Polyester Ltd on 23 June 2015. The decision concerns a situation where the scope of work accepted by the associated enterprise (AE) agent is wider than that of a comparable
See MoreIndia: High Court Rules on Use of Multiple Year Data and High-Profit Comparables
Recently, the High Court (HC) issued its decision in the transfer pricing case of Chrys Capital Investment Advisors (India) Pvt. Ltd v. DCIT (ITA No. 417 of 2014) on the usage of multiple year data and high-profit comparables on 27 April 2015. The
See MorePakistan: Compulsory Electronic tax return Filing for Individuals
The Federal Board of Revenue announced via Notification S.R.O. 791 (I) /2015 on 10 August 2015, that all individuals earning taxable salary income must file their income tax returns electronically. This will be effective from tax year 2015
See MoreIndia: Interest on tax refund taxable as business income under the India-UK tax treaty
Recently, the High Court in the case of B.J. Services Company Middle East Limited held that the interest earned on an income tax refund is taxable as business income under the India-UK tax treaty where the debt claim in respect of which interest
See MoreVietnam: Publishes Guidance on Tax Administration
Circular 110/2015/TT-BTC was issued on 28 July 2015 and provides guidance on tax administration and compliance by electronic means. The Circular replaces earlier Circulars 35/2013/TT-BTC and 180/2010/TT-BTC, and includes guidance on tax
See MoreSlovenia: Ministry of Finance Clarifies MAP under tax treaties
The Ministry of Finance published a document answering frequently asked questions (FAQs) concerning the mutual agreement procedure (MAP) under tax treaties on 17 August 2015. The answers provide, inter alia, the following clarifications: who may
See MoreSingapore: Corporate Tax Filing for 2015
The Inland Revenue of Singapore (IRAS) has reminded all companies to file their income tax returns for the 2015 assessment year by 30 November 2015. This is the first year that all companies in Singapore have the e-filing facility. All companies are
See MoreSingapore Publishes e-Tax guide to Mergers and Acquisitions Scheme
The Inland Revenue Authority of Singapore (IRAS) issued a revised e-Tax guide on 13 July 2015 to provide more details on the refinements to the mergers and acquisitions (M&A) scheme as recently stated in the Budget 2015. The complete e-Tax guide
See MoreJapan: Introduction of Tax Identification System from 2016
The National Tax Agency (NTA) of Japan has announced that a new tax identification number system ("My Number") will be introduced for both individuals and corporations in October 2015. The NTA will provide the 12-digit number to all relevant
See MoreWorld Tax Brief: June to July 2015
Austria Withholding tax on dividend distributions, capital gains: The withholding tax rate for dividends and capital gains will be increased to 27.5% (up from the current rate of 25%). If dividends are paid to corporations, a reduced withholding
See MoreDenmark: National Tax Tribunal Decision on foreign exchange losses on sale of shares
The Customs and Tax Administration published National Tax Tribunal Case No. 122-0208149 on 30 June 2015. The Tribunal held that foreign exchange losses realized on the sale of shares of a subsidiary resident in another Member State are not
See MoreProtocol to treaty between Austria and Belgium approved by Belgium
On 5 June 2015 the Belgian Council of Ministers approved the amending protocol, signed on 10 September 2009, to the Austria - Belgium Income and Capital Tax Treaty (1971). The protocol will be subject to the approval of the parliaments of the
See MoreAustria: Parliament and Federal Council approve Tax Reform Act 2015/16
The parliament (Nationalrat) and Federal Council (Bundesrat) approved the “Tax Reform Act 2015/16 (Steuerreformgesetz 2015/16)” with minor changes on 23 July
See MoreDTA between Singapore and Thailand signed
An Income Tax Treaty between Singapore and Thailand (2015) was signed on 11 June 2015. Once the treaty is in force and takes effect, this new treaty will replace the Singapore - Thailand Income Tax Treaty of
See MoreSingapore: Non-resident individual tax rates to increase from 2017
The Inland Revenue Authority (IRAS) announced on 12 June 2015 that tax rates for non-resident individuals will be increased from the year of assessment 2017 to maintain parity between the tax rates of non-resident individuals and the top marginal
See MoreIndia: Delhi Tribunal allows use of multiple-year data for purposes of determining arm’s length price
In the case of DCIT v. Innodata Isogen India Pvt. Ltd. , the Delhi Bench of the Income Tax Appellate Tribunal upheld a decision of the Commissioner of Income Tax (Appeals) to allow the taxpayer to use multiple-year data in determining the arm’s
See MoreIndia: Transfer Pricing Adjustment For Interest-Free Loan to Related Party
Recently, the Income-tax Appellate Tribunal upheld an interest adjustment on a loan that the taxpayer advanced to a related entity In the case of: Soma Textile & Industries Ltd. v. ACIT. Here the tribunal found that the comparable uncontrolled
See MoreSlovenia: Procedures for Advance Pricing Agreements
The Ministry of Finance has published proposed changes to the Slovenian Tax Procedure Act. The envisaged amendments bring a broad variety of important amendments regarding automatic exchange of information and elimination of administrative
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