Brazil: STF decides that interest on late tax refunds is non-taxable
On 24 September 2021, the Federal Supreme Court (Supremo Tribunal Federal, STF), ruled Extraordinary Appeal No. 1.063.187) that certain interest that a taxpayer receives on a late tax refund from the treasury should not be included in the
See MoreIndia: SC finds Mitsubishi is not liable for interest on late advance tax
On 17 September 2021, in the DIT vs Mitsubishi Corporation case, the Supreme Court ruled that a taxpayer should not liable for interest on late tax advances prior to fiscal 2012/2013 if the income payer failed to deduct the tax at source. The
See MoreUK: Statistics on Creative Industries Tax Relief
On 24 August 2021 HMRC published updated statistics for creative industries tax relief for 2020/21, showing that GBP 1.31 billion was paid out in tax relief for creative industries in 2020/21. Almost half the relief given in the period related to
See MoreTaiwan announces the amendments to the tax treaty rules and PE rules
On 12 August 2021, Taiwan’s Ministry of Finance has announced the amendments to the “Regulations Governing Application of Agreements for the Avoidance of Double Taxation with Respect to Taxes on Income”. The amended regulations have come into
See MoreBotswana enacts budget for 2021/22
On 30 June 2021, the Minister of Finance and Economic Development published a press release announcing the implementation of the budget for 2021/22. The most important measures are: -The general withholding tax rate increased from 7.5% to 10% on
See MoreOECD: Research and Development Tax Incentives and Effective Tax Rates
On 28 July 2021 the OECD published on its website tax working paper no 54 entitled Corporate Effective Tax Rates for R&D: The case of expenditure-based R&D tax incentives, written by Ana Cinta González Cabral, Silvia Appelt and Tibor
See MoreKenya: Tax Appeal Tribunal issues rule on a case of management fees
On 1 April 2021, the Kenyan Tax Appeals Tribunal (TAT) ruled on tax disputes between McKinsey and Company Inc. Africa Limited (McKinsey / the Appellant) and the Kenya Revenue Authority (KRA / the respondent) in relation to withholding tax (WHT) on
See MoreUK: Call for Evidence on Employee Management Incentives
Employee management incentives (EMIs) were introduced in the UK to provide small and medium enterprises (SMEs) with an additional way to remunerate their employees. This can be of benefit to small, innovative companies that need to recruit the
See MoreUK: Consultation on Research and Development Tax Reliefs
Following the announcement in the UK Budget on 3 March 2021 of a consultation on the research and development (R&D) tax relief the UK government has issued a consultation document. The UK currently offers two main tax reliefs to companies
See MoreUK Budget Announcements for 2021
On 3 March 2021 the Chancellor announced the UK budget provisions for 2021. The furlough scheme, which pays 80% of employees' wages, will be extended until the end of September 2021, but employers will be asked to contribute 10% in July and 20%
See MoreSouth Africa: Court makes a decision regarding TP methods
On 7 January 2021, in the case of: ABC (Pty) Ltd v. Commissioner (IT 14305) ZATC 1, the South African Court upheld a transfer pricing adjustment for a taxpayer that failed to have transfer pricing documentation to support the arm’s
See MoreOECD: Forum on Tax Administration Agrees Action on Administrative Challenges
On 8 December 2020 representatives of the members of the OECD’s Forum on Tax Administration (FTA) agreed on an agenda for 2021 focusing on tax certainty and digital enhancement of tax administration. The FTA is a global forum on tax
See MoreBulgaria: Government imposes penalty for late application of tax treaty relief
On 18 November 2020, parliament passed amendments to the Tax and Social Security Procedure Code at first reading, which aims to ensure the payment of withholding tax on cross-border payments and the effectiveness of tax control in the event of
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UK: Updated Statistics on Transfer Pricing and Diverted Profits Tax
On 12 November 2020 HMRC published updated statistics relating to transfer pricing and the diverted profits tax for 2019/20 (the year to 31 March 2020). In 2019/20 a total of 125 transfer pricing enquiries were settled, with an average
See MoreECJ: Ruling on Transfer Pricing Treatment of Bank Transfers Between Branch and Parent
On 8 October 2020 the European Court of Justice (ECJ) ruled on Romania’s transfer pricing rules in relation to bank transfers from a branch to a head office that is located in another EU Member State. Impresa Pizzarotti concluded two loan
See MoreOECD: Economic Survey of UK
On 14 October 2020 the OECD published on its website its economic survey of the UK. The outlook for the UK is uncertain with the combination of Brexit and the COVID-19 crisis. Since July 2020 the UK has begun a new phase of support for business
See MoreCzech Republic: Supreme Court makes a decision regarding transfer pricing issues
Recently, the Supreme Administrative Court has issued a landmark decision for companies that have incentives to invest in older systems. The court confirmed that failure to meet the condition not to increase the tax base for calculating tax relief
See MoreDenmark: National tax court clarifies TP documentation rules for intergroup companies
On 24 September 2020, the Danish Tax Administration published a Decision No. SKM2020.387.LSR, clarifying the transfer pricing documentation requirements for a change of business structure within a group company. The case concerns a Danish
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