European 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
See MoreIMF Comments on Senegal’s Economic Plans
The IMF Country Report No 15/2 issued in January 2015 concerned the annual bilateral discussions with Senegal and includes a staff report by the IMF team and a debt sustainability analysis. The IMF notes that Senegal is committed to implementing the
See MoreECJ rules in case concerning VAT on letting of immovable property
The European Court of Justice (ECJ) ruled on 22 January 2015 in the case of Regie Communal Autonome du Stade Luc Varenne v Etat Belge. A preliminary question had been put to the ECJ concerning VAT on leasing of immovable property. This case
See MoreECJ: Advocate General’s opinion on X AB Case
The Advocate General of the European Court of Justice (ECJ) issued an opinion on 22 January 2015 in the case of X AB v Skatteverket. In this case the Supreme Administrative Court of Sweden had asked the ECJ for a preliminary ruling on whether
See MoreOECD Holds Public Discussion on Dispute Resolution Mechanisms
On 23 January 2015 the OECD held a public discussion on action 14 of the base erosion and profit shifting (BEPS) action plan on how to make dispute resolution mechanisms more effective. The Chair of the Focus Group on Dispute Resolution presented to
See MoreOECD Holds Public Meeting on the Prevention of Treaty Abuse
On 22 January 2015 the OECD held a public consultation meeting to discuss the base erosion and profit shifting (BEPS) action 6 on the prevention of tax treaty abuse. The issue as presented in the OECD’s discussion draft on this issue and the
See MoreCanada: Customs Notice permits import duty refund claims on transfer pricing adjustments
Basically, Customs Notices are issued to inform clients about proposed changes to customs procedures. Customs Notice N-15-001 has been published by the Canada Border Services Agency (CBSA) for deleting an obstacle to file import duty refund claims.
See MoreWTO Launches Process to Agree Doha Programme
A meeting was held on 21 January 2015 at which the Director General of the World Trade Organization (WTO) began a new consultation process aimed at agreeing on a programme of work to discuss the remaining Doha Development Agenda issues by July 2015.
See MoreOECD Publishes Comments on Transfer Pricing for Low Value Adding Intragroup Services
Intragroup services would include centralized services such as administration, accounting, legal, computer, staff matters and training, which are all considered to be intragroup services. Arm’s length charge Having determined that the services
See MoreOECD publishes comments on prevention of artificial avoidance of PE status
On 13 January 2015 the OECD published on its website the comments received from interested parties on the discussion draft in respect of Action 7 of the action plan on base erosion and profit shifting (BEPS). This concerns prevention of artificial
See MoreOECD publishes comments received on restriction of treaty benefits
On 13 January 2015 the OECD published on its website the comments received from interested parties on Action 6 of the action plan on base erosion and profit shifting (BEPS). This concerns the prevention of tax treaty abuse and involves developing
See MorePhilippines: Personal income tax reforms
The Tax Management Association of the Philippines (TMAP) has raised a concern to revamp the Personal Income tax threshold and tax brackets. To ensure secure revenue collection levels, TMAP has recommended a raise on Personal Income Tax (PIT) exempt
See MoreCanada: Comments for OECD discussion draft on international VAT-GST guidelines
The Organization for Economic Co-operation and Development (OECD) has published a discussion draft on 18th December 2014 entitled “Guidelines on Place of Taxation for Business-to-Consumer Supplies of Services and Intangibles and Provisions on
See MoreBelgium Federal Budget for 2015
Recently, the Belgian Government was gazettes the following federal end of year tax measures for corporate income tax in the State Gazette: Changes regarding Corporate income tax: The corporate income tax exemption for communal joint-venture
See MoreSingapore: New Revised Transfer Pricing Guidelines for 2015
The Inland Revenue Authority of Singapore (IRAS) publishes revised transfer pricing (TP) guidelines on 6 January 2015. The 2015 TP Guidelines are generally in line with the OECD Transfer Pricing Guidelines (2010) as well as some relevant areas of
See MoreSingapore: Publishes e-Tax Guide on Transfer Pricing
The Inland Revenue Authority of Singapore (IRAS) has releases second edition of Transfer Pricing Guidelines on January 6, 2015. The e-Tax guide is separated into three main parts and it discusses ways to resolve transfer pricing disputes. It also
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