India: Section 14A is subject to dividend income tax regardless of dividend distribution tax (DDT) Payment
Section 14A of the Income Tax Act, 1961 (Act) provides for disallowance of expenditure incurred in relation to income which is not included in the total income of the assessee. The Supreme Court of India in the case of Godrej & Boyce
See MoreItaly: Detail corporate tax measures mentioned in Budget Law for 2017
The Italian Budget Law for 2017 entered into force on 1 January 2017. From 2017 financial year, the Italian corporate income tax ("CIT") standard rate is reduced from 27.5% to 24 %. However, Banks, parent companies of banking groups, individual
See MoreFrance-amending Finance Bill for 2016
The Amending Finance Bill for 2016 (projet de loi de finances rectificative pour 2016, PLFR) (the Bill) was presented by the government and submitted to the National Assembly on 18 November 2016. The Ministry of Finance of France announced to
See MoreArgentina: Publishes significant tax changes
On July 22, 2016, Law 27,260, with special incentives for Argentine taxpayers businesses to report previously unreported foreign and domestic assets, was published in the Argentine Official Gazette. The law includes modifications to various tax
See MoreUK publishes text of double tax agreement with Uruguay
On 28 June 2016 the UK published the text of the double tax convention with Uruguay signed on 24 February 2016. The agreement is not yet in force. The provisions of the agreement generally follow the OECD Model but the following items are of
See MoreFrance-public consultation launched on 1% add-back on dividends within tax-consolidated groups
The Tax Administration of France published on 11 May 2016 guidelines on the taxation of dividends distributed within tax-consolidated groups following changes brought by the Amending Finance Law 2015. For financial years commencing on or after 1
See MoreRussia: Amendment of tax law implements in 2016
In Russia, recently important tax laws were passed for corporate taxation from 2015 onwards, which will take effect from 2016. The major changes are given below: In 2016, an interest rate threshold from 75% to 125% for the Central Bank will apply
See MoreCanada: WHT relief for foreign employers of cross-border workers
Under Regulation 102 of the Income Tax Act, non-Canadian resident employers with non-resident employees working in Canada can now apply to qualify for a new exception from the withholding tax requirements. Under the provisions of many of the double
See MoreUK-Sweden double tax agreement enters into force
The double taxation agreement (DTA) signed by the UK and Sweden on 26 March 2015 entered into force on 20 December 2015. The new agreement replaces the previous bilateral DTA between the two countries signed in 1983. The agreement takes effect in
See MoreFrance-Approved Finance Bill 2016 and amended Finance Bill 2015
The French Parliament approved the Finance Bill for 2016 and and the amended Finance Bill for 2015 on 17 December 2015. The Finance Bill enacts the country-by-country (CbC) reporting requirement into the legislation of France. From 1 January 2016
See MoreFrance: New Tax Laws Permit Sister Companies To Consolidate
France’s 2015 Finance Act and the Rectificative Finance Act for 2014 have entered into force. According to new law, the changes are below; New rules permitting sister companies to f for tax purposes. A reduction in the real estate
See MoreSouth Africa: SARS Issues Guidance on Double Taxation Relief
The South African Revenue Service (SARS) has issued a draft interpretation note for comment on the rebates and deductions available in the country's tax code for foreign taxes on income. The note points out that residents of South Africa are subject
See MoreTurkey – CIT relief from certain services
A circular provides for the possibility of exempting 50% of the profit provided to non-residents for corporate income tax purposes and earned by Turkish taxpayers from certain types of services. Now, companies who may benefit from the 50% relief
See MoreIsrael: Action required for releasing trapped profits by 11 November 2013
Only those companies have to apply the temporary partial relief from Israeli corporate income tax until 11 November 2013, who wish to release their trapped exempt profits that were accrued until December 31, 2011. Companies will have to submit their
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