UK: Statistics on Research and Development Tax Relief
On 30 September 2020 HMRC published the statistics for claims for research and development (R&D) tax relief in the UK. By monitoring tax relief schemes HMRC can examine the level of use of the schemes and gain some insight into the
See MoreUK: Statistics on Patent Box Tax Relief
The patent box legislation allows companies in the UK to apply a lower corporation tax rate to profits earned from qualifying patented inventions and specified equivalent types of intellectual property. The relief was first introduced from 1 April
See MoreEU: Sectoral Policies for Climate Change Mitigation
On 16 September 2016 the EU published a departmental paper entitled Sectoral Policies for Climate Change Mitigation in the EU. The paper examines climate mitigation policy in five sectors that in aggregate account for 95% of greenhouse gas
See MoreCanada: The Tax Court makes a decision in a case regarding transfer pricing dispute
On 27 August 2020, the Tax Court of Canada made a decision in a case, Canada vs AgraCity Ltd. and Saskatchewan Ltd., in favor of Candian company AgraCity Ltd. and related company, Saskatchewan Ltd. The AgraCity Canada had entered into a Services
See MoreWorld Bank: Vietnam must boost new drivers of growth
On 30 July 2020 the World Bank issued an economic update entitled What will be the new normal for Vietnam: the economic impact of COVID-19?. Vietnam has been successfully fighting the COVID-19 crisis but GDP growth has suffered a fall of almost
See MoreUK: Statistics on creative industries tax relief
HMRC published updated statistics for creative industries tax relief for 2019/20 on 13 August 2020, showing that GBP 1.11 billion was paid out in tax relief for creative industries in 2019/20. Almost half the relief given related to film tax relief
See MoreUK: Consultation on Extension of R&D Tax Credits to Data and Cloud Computing
On 21 July 2020 the UK government launched a consultation on extending research and development (R&D) tax credits to costs relating to data and cloud computing. Comments are invited by 13 October 2020. R&D tax credits support innovative
See MoreUK: Amendments to the Restriction on the Tax Deduction for Interest
On 21 July 2020 the UK published draft legislation to amend the limitation on the interest deduction for corporation tax. This would be part of the Finance Bill for 2020/21. The rules to limit the corporation tax deduction for interest were
See MoreCanada: Federal Court of Appeal makes a decision on a case regarding GAAR
On 5 May 2020, the Federal Court of Appeal has made a decision on a case entitled, “2018 TCC 187”, which was against the tax authorities, but in favor of the Tax Court of Canada's decision or the taxpayer. The Federal Court finds that the loss
See MoreIMF: Fiscal Monitor discusses policies to support individuals and businesses
The April 2020 issue of the IMF’s Fiscal Monitor discusses policies to support individuals and businesses through the coronavirus crisis and the resulting economic problems. The Fiscal Monitor looks at certain temporary and targeted fiscal
See MoreECJ: Decision on State Aid and Turnover Tax
On 3 March 2020 the European Court of Justice (ECJ) issued a decision in Vodafone Magyarország Mobil Távközlési Zrt. The company was a subsidiary of Vodafone Europe B.V operating in the telecommunications market and set up under Hungarian law.
See MoreECJ decision on compatibility of progressive turnover tax with EU law
On 3 March 2020 the European Court of Justice (ECJ) issued a decision in the case of Tesco-Global Áruházak Zrt. The company, a part of the Tesco plc group, was a public limited company set up under Hungarian law operating in the wholesale and
See MoreOECD: Transfer Pricing Guidance on Financial Transactions
On 11 February 2020 the OECD released a report entitled Transfer Pricing Guidance on Financial Transactions: Inclusive Framework on BEPS: Actions 4, 8-10. The OECD reports on base erosion and profit shifting (BEPS) issued in 2015 requested
See MoreUK: Statistics on Transfer Pricing and Diverted Profits Tax
On 27 January 2020 HMRC published statistics relating to transfer pricing and the diverted profits tax. HMRC had 441 full time equivalent staff working on international tax issues involving multinational groups in 2018/19, including transfer
See MoreDenmark: National Tax Court publishes a decision on the scope of controlled transaction
On 3 January 2020, the National Tax Court published a decision regarding a Case dealing with controlled transactions that "transactions" also include a provision where there is a capital reduction in a company, which is carried out by a reduction
See MoreHigh Court rules that the Danish loss-making company could not deduct royalties paid to its Swiss parent
On 28 October 2019, the Eastern High Court of Denmark published a case (Denmark vs Adecco; Case No SKM2019.537.OLR of 4 July 2019) decision and agreed with the tax authority that a Danish loss-making company could not deduct royalties paid to its
See MoreNigeria: Tribunal issues decision in a case on dividends paid from tax exempt income
The Tax Appeal Tribunal issued a decision in a case entitled “United Capital Asset Management Ltd and United Capital Trustee Ltd v. Federal Inland Revenue Service” on the application of excess dividend tax in terms of section 19 of the
See MoreIndia: ITAT ruled that the Liaison Office of Hitachi constitutes a PE
On 17 September 2019, the Delhi Bench of the Income Tax Appellate Tribunal (ITAT) in the case of: Hitachi High Technologies Singapore Pte Ltd vs. DCIT , held that a Liaison Office (LO) of Hitachi Technologies Singapore Pte Limited constituted a
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