Transfer Pricing Brief: April 2015
UK: BEPS Country-by-Country Reporting Requirement: Clause 122 of the Finance Bill gives the UK Treasury the power to make regulations for implementing the guidance of the OECD on country-by-country reporting. This would be part of the transfer
See MoreUnited States: ADD/CVD Roundup for April 2015
Following table shows the Federal Register notices related to ADD/CVD cases for April 2015 in United States. Australia Silicomanganese Determination A-602-808 See the Federal Register notification Brazil Prestressed Concrete Steel Wire
See MoreUnited States: ADD/CVD Roundup for March 2015
Following table shows the Federal Register notices related to ADD/CVD cases for March 2015 in United States. Country Product Investigations Case Number Details Australia Silicomanganese Initiation of Less-Than-Fair-Value
See MoreTax Treaty News: March 2015
Sweden United Kingdom On March 26, 2015, the DTA between Sweden and United Kingdom was signed, in Stockholm. Once in force and effective, the new treaty will replace the existing DTA of 1983. Bulgaria United Kingdom On March 26, 2015,
See MoreTransfer Pricing Brief: March 2015
Australia Transfer pricing rule-The practice statement (PS LA 2015/3) issued on 26 February 2015 sets out a new internal approval process for application of the reconstruction provisions. See the Story in
See MoreTax Treaty News: February 2015
Turkey and Kosovo The Turkish Council of Ministers ratified the DTA between Turkey and Kosovo as published in the Official Gazette of 27 February 2015. Japan and Qatar On February 20, 2015, Finance Ministry of Japan issued a press release
See MoreUnited States: ADD/CVD Roundup for February 2015
Following table shows the Federal Register notices related to ADD/CVD cases for February 2015 in United States. Country Product Investigations Case Number Details Australia Certain Uncoated Paper Initiation of Less-Than-Fair-Value
See MoreTransfer Pricing Brief: February 2015
France Penalty for Documentation FailureThe Finance Act, 2015 provides that for tax audits initiated from 1 January 2015 penalties for inadequate documentation are the higher of EUR 10,000 per entity per period under audit; 0.5% of the total
See MoreUnited States: ADD/CVD Roundup for January 2015
Following table shows the Federal Register notices related to ADD/CVD cases for January 2015 in United States. Country Product Investigations Case Number Links Australia Electrolytic Manganese Dioxide Revocation of the Antidumping Duty Order
See MoreTax Treaty News: January 2015
Italy and Jersey On January 26, 2015, the TIEA between Italy and Jersey entered into force. Belgium and Czech Republic On January 13, 2015, the protocol amending the DTA between the Belgium and Czech Republic entered into force. Hungary and
See MoreTransfer Pricing Brief: January 2015
Australia Requirement for Transfer Pricing Documentation- Taxpayers with a high risk transfer pricing profile will be held to more stringent requirements. Transfer Pricing Audits Penalty in Cases of Adjustments-25% penalty applies
See MoreTax Treaty News: December 2014
Canada - UK On December 18, 2014, the amending protocol of the Income Tax Treaty between Canada and United Kingdom has entered into force and that was signed on 21st July 2014. Japan - UK On December 12, 2014, the Income Tax Treaty between
See MoreTransfer Pricing Brief: December 2014
Argentina Compliance-Decree 2103/2014 created a special unit to monitor cross-border trade and coordinate the work of the various government bodies to ensure the correct application of the law on international trade. Australia Transfer
See MoreWorld Tax Brief : December 2014
China Incentives on Industry/manufacturing : Circular Cai Shui no 59 has extended the 15% tax rate to Technologically Advanced Service Enterprises (TASEs) in 21 trial cities until 31 December 2018. These must provide qualifying services and
See MoreTax Treaty News: November 2014
Austria - Belarus On November 24, 2014, Belarus signed a protocol to amend its Double Taxation Agreement (DTA) with Austria. Kazakhstan - Czech Republic On November 24, 2014, The Czech Republic signed a protocol to amend its Double Taxation
See MoreTransfer Pricing Brief: November 2014
Australia Transfer Pricing Rule-The reconstruction provisions are contained in section 815-130 ITAA 1997. TR 2014/6 gives guidance on identifying situations where the form of commercial or financial relations differs from the
See MoreWorld Tax Brief : November 2014
Chile Main corporate tax rates: Under the Law 20,780A, 20% of tax rate applies in 2014 to Chilean companies or permanent establishments of foreign companies. Under legislation enacted in September 2014 the corporate income tax rate will rise to
See MoreTax Treaty News: October 2014
South Korea - Andorra On October 23, 2014, The Republic of Korea signed a Tax Information Exchange Agreement (TIEA) with Andorra. Switzerland - Australia On October 14, 2014, The Double Taxation Agreement (DTA) between Switzerland and
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