OECD releases discussion draft on cost contribution arrangements
On 29 April 2015 the OECD released a discussion draft on cost contribution arrangements. The draft is part of action 8 of the OECD/G20 action plan on base erosion and profit shifting (BEPS) aiming to ensure that transfer pricing outcomes are in line
See MoreOECD: Further BEPS discussion drafts planned for May 2015
Further discussion drafts are to be issued in May 2015 as part of the OECD/G20 action plan on base erosion and profit shifting (BEPS). A discussion draft on cost contribution arrangements is planned for around the end of April 2015. This is part of
See MoreECJ ruling on exemption from capital duty under the Capital Duty Directive
On 22 April 2015 the European Court of Justice (ECJ) delivered its ruling in the case of Drukarnia Multipress. Drukarnia was a Polish limited liability company that intended to carry out a conversion into a limited joint-stock partnership (SKA) and
See MoreUK: Joint initiative with Australia to combat profit shifting
The Australian Treasurer issued a press release following the G20 meeting on 16 and 17 April indicating potential collaboration with the UK to combat profit shifting. The UK government introduced a Diverted Profits Tax with effect from 1 April
See MoreOECD releases discussion draft on improving the analysis of BEPS
On 16 April 2015 the OECD released a discussion draft on improving the analysis of base erosion and profit shifting (BEPS) actions. This relates to action 11 of the BEPS action plan that concerns improving the availability and analysis of data on
See MoreCanada: Highlights of Pre-election Federal Budget 2015
The Finance Minister delivered the Government’s 2015 pre-election federal budget on 21st April 2015. The tax highlights in the 2015 budget are given below: From the beginning of 2015, the limit for annual contributions to a tax-free savings
See MoreNamibia: Budget proposals for 2015-16
The Namibian budget speech for 2015-16 was delivered on 31 March 2015. In the budget it was proposed to reduce the corporate income tax rate for non-mining companies from 33% to 32%. There will be no change in the corporate tax rate for mining
See MoreTurkey: Notional interest deduction as incentive for capital
The Parliament has accepted a law 6639 entitled “notional interest deduction” on 7th April 2015. This new law gives a tax incentive for cash capital contribution increases, effects after 1st July 2015. Excluding those operating in the finance,
See MoreJapan: 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 MoreOECD releases discussion draft on CFC rules
Action 3 of the OECD/G20 action plan on base erosion and profit shifting (BEPS) is concerned with taking action on controlled foreign company (CFC) rules. These rules benefit the country of the ultimate parent of a group by subjecting more profits
See MoreOECD releases discussion draft on mandatory disclosure rules
On 31 March 2015 the OECD released a discussion draft in respect of Action 12 of the action plan on base erosion and profit shifting (BEPS). Action 12 calls for disclosure initiatives to deal with the lack of relevant information for tax
See MoreCyprus-OECD Convention and protocol on Mutual Administrative Assistance in Tax Matters enters into force
The multilateral convention and protocol between Cyprus and OECD regarding mutual administrative assistance in tax matters entered into force on 1 April 2015. The convention and the protocol were signed on 10 July, 2014. The convention and the
See MoreVietnam: Publishes Decree No. 12 on corporate income tax
Decree No. 12/2015/ND-CP (Decree 12), on the implementation of Law No. 71/2014/QH13 dated 26 November 2014 was issued on 12 February 2015. Decree 12, which is effective from 1 January 2015, supplements and amends a number of tax laws. The main
See MoreOECD: Meeting of Task Force on Tax and Development
On 18 March 2015 the OECD’s Task Force on Tax and Development met to consider the input resulting from regional network meetings on base erosion and profit shifting (BEPS). The meeting also considered capacity building support provided to
See MoreOECD holds public consultation on transfer pricing issues
On 19 and 20 March 2015 the OECD held a public consultation on transfer pricing matters arising from the action plan on base erosion and profit shifting. The first day of the conference dealt with the draft amendments and additions to Chapter 1 of
See MoreEuropean Commission Presents Tax Transparency Package
On 18 March 2015 the European Commission issued a range of measures aimed at tacking corporate tax avoidance and harmful tax competition. Corporate tax avoidance distorts economic decisions and prevents fair competition. The complexity of tax rules
See MoreECJ requested to give a preliminary ruling on pension surtax
The European Court of Justice (ECJ) was requested by Finland’s Supreme Administrative Court (KOH) on 6 March 2015 to give a preliminary ruling in respect of the pension surtax. Finland has imposed a surtax of 6% on large pensions since 2013. The
See MoreECJ: Preliminary ruling in case on VAT exemption for welfare and social work
On 12 March 2015 the European Court of Justice (ECJ) gave its preliminary ruling in the case of “go fair” Zeitarbeit OHG (C-594/13). The ECJ had been requested by the German Bundesfinanzhof to respond to questions in respect of the VAT exemption
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