United Kingdom – Supreme Court addresses cross-border group losses
The UK Supreme Court on 19 February 2014 issued its judgment relating to three remaining issues in the Marks & Spencer case—i.e., the case addressing a cross-border group relief claims. The Court found that the conditions for the “no
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 MoreCanada -Partnership information return for 2013
The Canadian Revenue Agency (CRA) has issued revised guidance for partnership information returns (Guide T4068), Guide for the Partnership Information Return (T5013 Forms) for the year 2013. The Guide T4068 contains changes to the forms, schedules
See MoreSpain: Transactions exceeding €1 million need to report
Companies holding balances or conducting transactions during 2013 with foreign companies that exceed €1 million is required to report. This new reporting requirement impact companies in Spain as well as international multinational entities with
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
See MoreUK: HM Revenue and Customs (HMRC) revises SDLT group relief regulations
The UK tax authority HMRC has introduced a clarification confirming that intra-group transactions are eligible for group relief related to Stamp Duty Land Tax (SDLT). The declaration follows a meeting by HMRC with representative bodies concerning
See MoreECJ: Decision on state aid and Finland’s tax loss carry forward rules
A case was brought before the European Court of Justice (ECJ) concerning the question of whether Finland’s rules for carrying forward tax losses were contrary to the state aid provisions in Article 107 of the Treaty on the Functioning of the
See MoreECJ: European Commission refers the matter of cross-border loss relief for UK groups
The European Commission has requested the European Court of Justice (ECJ) to determine that the conditions imposed by the UK tax rules on cross-border group relief mean that in practice it is almost impossible for companies to receive this loss
See MoreUkraine: Draft Law amendments regarding the formation of a tax group
Draft Law No. 2737 introduces amendments regarding the formation of a tax group. On 5 April 2013, amendments to the Tax Code were sent to be approved by the parliament. The legislation will allow companies in Ukraine to form a consolidated tax group
See MoreAustria:Corporate tax guidelines limit interest deductions
The Austrian Ministry of Finance published revised corporate income tax guidelines in March 2013, to tightening the rules with respect to interest deductions in connection with “debt push-down models” and concerning tax loss carry forwards
See More