South Africa: Proposal to ChangeTransfer Pricing Documentation and CFC Rules
The South African Finance Minister Nhlanhla Nene proposed new transfer pricing documentation and reporting rules and proposed to revise controlled foreign company (CFC) rules relating to the digital economy, in his budget speech for 2015. The
See MoreIMF-JICA conference supports inclusive growth for Asian frontier and developing economies
The third conference held by the IMF and JICA (the Japan International Cooperation Agency) has discussed the participation of frontier and developing countries in Asia in economic growth. In his opening remarks the deputy managing director of the
See MoreECJ rules on applicability of national procedures in abusive practices
On 12 February 2015 the European Court of Justice (ECJ) gave a preliminary ruling on a value added tax (VAT) case that had been referred to it by the Portuguese Supreme Administrative Tribunal. The question raised In the case of Surgicare - Unidades
See MoreOECD holds webcast to provide updates on the BEPS project
On 12 February 2015 the OECD held a webcast to update interested parties on the progress made in the action plan on base erosion and profit shifting (BEPS). The OECD and G20 countries have agreed on three elements that will enable implementation of
See MoreUK issues VAT instructions following the Skandia judgment
On 10 February 2015 the UK tax authority HMRC issued Revenue and Customs Brief 2 (2015) on VAT grouping rules and the Skandia judgment. Skandia was a US corporation with a branch in Sweden. The branch in Sweden became part of a Swedish VAT group
See MoreEgypt: IMF recommends introduction of a full VAT system
Following consultations in Egypt under Article IV of its articles of agreement the International Monetary Fund (IMF) has reported that measures implemented have begun to produce a turnaround in the economic situation in Egypt after the years of
See MoreOECD publishes comments received on limiting base erosion through financial payments
On 11 February 2015 the OECD published on its website comments received from interested parties in respect of the discussion draft on interest deductions and other financial payments, corresponding to action 4 of the OECD/G20 action plan on base
See MoreOECD publishes comments received on transfer pricing aspects of commodity transactions
The OECD has published on its website comments received on the discussion draft on the transfer pricing aspects of cross border commodity transactions. This was issued as part of the response to action 10 of the base erosion and profit shifting
See MoreOECD publishes comments received on draft changes to the transfer pricing guidelines
On 10 February 2015 the OECD published comments received in respect of the discussion draft on changes to the OECD guidelines and other special measures that could be taken in respect of transfer pricing issues raised by actions 8, 9 and 10 of the
See MoreIndia: Amendments to Transfer Pricing Guidelines Issued
The Central Board of Direct Taxes released amendments to the transfer pricing guidelines on 4 February 2015. The “simplified” transfer pricing documentation rules were released by a notification dated 4 February 2015 for domestic transactions of
See MoreOECD to present BEPS action plan developments to the G20 Finance Ministers
The OECD is to give a presentation on the project on base erosion and profit shifting (BEPS) to the G20 Finance Ministers when they meet on 9 and 10 February 2015. The OECD has agreed with the G20 countries on three important elements that will move
See MoreIMF reports on Costa Rican economy
The IMF has concluded its discussions with Costa Rica under Article IV and issued a report on 4 February 2015. Costa Rica currently has problems of weak growth and rising unemployment. The IMF is recommending budget consolidation to improve the
See MoreIreland: VAT Rates on Stock Exchange Fees
The tax authority of Ireland, the Revenue Commissioners, has updated Part 5.69 of its value-added tax (VAT) manual to explain the VAT treatment related to stock exchange fees. The guidance contains fees for firms trading securities on the Irish
See MoreSlovak Republic: Proposal for VAT due on payment from customer
A pending proposal regarding the time when the VAT is to be remitted would revise in Slovak Republic. So VAT would be due at the time of customer payment received. It would affect when an input VAT deduction claim could be made. It is expected that
See MoreSouth Africa: Transfer Pricing Adjustments Regarding Withholding Tax Obligations
Under the income tax act, section 31(3), South Africa provide that any adjusted amount for transfer pricing and thin capitalization purposes, prior to 1 January 2015, constituted a deemed loan. The adjusted amount plus interest deemed to have
See MoreEuropean Union: Anti abuse clause added to parent subsidiary directive
On 27 January 2015 the Council of the European Union (EU) amended the parent subsidiary directive to add a binding anti-abuse clause. This is designed to prevent tax avoidance and aggressive tax planning, and to ensure more consistency in the
See MoreEU: sets up new mandate for the Joint Transfer Pricing Forum
As the previous mandate for the EU Joint Transfer pricing Forum had expired, on 26 January 2015 the European Commission issued Commission Decision C (2015) 247 in respect of setting up a new EU Joint Transfer Pricing Forum expert group. The previous
See MoreIndonesia: Plans to Introduce VAT on E-Commerce
The Finance Minister of Indonesia has confirmed their plan to introduce value-added tax (VAT) on e-commerce. In order to implement this plan, the Ministry of Communications and Information Technology has been asked to prepare regulations to tax
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