India: High Court affirms that comparables must be functionally similar
In the case of: CIT-I v. DSM Anti Infectives India Ltd. ITA No. 116 of 2014 the Punjab and Haryana High Court confirmed a judgment of a tax appellate tribunal that certain companies selected in a search for comparables in a transfer pricing analysis
See MorePakistan: Budget for 2015/16
The Budget for the fiscal year 2015/16 (tax year 2016) was presented on 5 June 2015. The Budget proposals will basically take effect from 1 July. The proposed measures are summarized below: Corporate Tax: The corporate income tax rate is to be
See MoreIndia: Delhi High Court Expresses Its View on Marketing Intangibles
Recently, the Delhi High Court issued its much anticipated ruling on marketing intangibles in the Sony Ericsson Mobile Communications India Pvt. Ltd. case. The High Court ruling is partially in favor of the taxpayers engaged in the import,
See MoreNew Zealand: Minister of Finance presents the Budget for 2015/2016
The Minister of Finance presented the Budget for 2015/2016 to Parliament on 21 May 2015. The Budget 2015/2016 deals only with domestic tax issues. The Budget contains the following proposals: Strengthening the tax rules applicable to property
See MoreWorld Tax Brief: May 2015
Indonesia Incentives: On 6 April 2015, the government grants regulation (GR) No. 18 of 2015 (GR 18/2015) regarding the income tax incentive facilities available for investments in specified business sectors and regions. This regulation is
See MoreDenmark: Parliament Enacts Law to Combat Tax Evasion
The Danish parliament has adopted a law proposal (L 167) that includes some of the measures agreed on in the package of proposals to combat tax evasion. The law covers the following measures: The control of foreign trusts is improved in order
See MoreWorld Tax Brief : March & April 2015
United Kingdom Main Corporate tax Rate: The main rate of Corporation Tax for 2015 is 20% (With the exception of oil and gas companies with ring fence profits) from 1 April 2015. The Corporation Tax will be charged at a single rate known as the
See MoreDenmark: Minister of Taxation Clarifies Danish Treaty Policy
The Ministry of Taxation published a press release summarizing the statements given by the Minister to Parliament on 29 April 2015 in an open hearing regarding the Danish treaty policy. The main emphasis of the hearing was the conclusion of tax
See MoreWorld Tax Brief : January & February 2015
Belgium Taxability of other income: From 2015 small and medium sized companies may create a "liquidation reserve" from after-tax profits. The liquidation reserve is immediately subject to a separate tax of 10%. Upon liquidation, no dividend
See MoreIndia: Elements for Including or Excluding Comparable Companies
In the case of Chrys Capital Investment Advisors (India) Pvt. Ltd. v. DCIT ITA No. 417 of 2014, the Delhi High Court confirmed a verdict of the Delhi Bench of Income-tax Appellate Tribunal that if a company has high or extremely high profits and
See MoreAustria: First Details of Tax Reform
The Ministry of Finance published the first details of the planned Tax Reform on 20 March 2015. The amendments will generally be applicable with effect from 1 January 2016. Main changes of the reform are as follows: Individual tax: Reduction of
See MoreAustria: Ministry of Finance Publishes Guidance on Mutual Agreement and Arbitration Procedures
The Ministry of Finance published guidance on 31 March 2015 regarding mutual agreement and arbitration procedures under tax treaties and under the EU Arbitration Convention (90/436 on the Elimination of Double Taxation in connection with the
See MoreChina: Publishes new annual corporate income tax return package
State Administration of Tax issued Annual Corporate Income Tax Return Package of People's Republic of China (Type A, 2014). The new return package will come into force on Jan 1st, 2015 and first to be adopted by resident CIT taxpayers in the 2014
See MoreTreaty between Austria and Romania: Romanian Ministry of Finance Clarifies Taxation of Interest
The Romanian Ministry of Finance (MoF) issued Circular No. 674003 on 20 January 2015, expounding the taxation of interest payments under the Austria-Romania Income and Capital Tax Treaty. Main Changes are: According to article 11, paragraph 2 of
See MoreIndia: High Court Decision on Cross-border Loan Transaction
The Delhi High Court in the case of:  CIT v. Cotton Naturals India Pvt. Ltd. [ITA No. 233/2014 (AY 2007-08) (Delhi High Court) concerning the benchmarking of the rate of interest on an inter-company loan made to a foreign related party—held that
See MoreEgypt Publishes Preliminary Budget for 2015-2016
The Ministry of Finance issued a preliminary statement on 18 March 2015, for the 2015-2016 Budget. The statement highlighted the following changes: The standard corporate tax rate will be reduced to 22.5%. The new rate is expected to apply for
See MoreJapan: Â Approves Proposed tax Reforms
The National Diet has passed the proposed 2015 tax reforms and circulated the amended tax laws on 31 March 2015 with minor changes. From 1 April 2015, the corporation tax rate will be reduced to 23.9%. The effective rate for large companies is
See MoreProtocol to treaty between Belgium and Vietnam approved by Belgium
The Belgian Council of Ministers approved the amending protocol to the Belgium-Vietnam double tax agreement on 3 April 2015. The amending protocol was signed on 12 March
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