Norway: Exemption from withholding tax applies
The tax authorities released a "binding advance ruling" (BFU / 17, 4 May 2017) regarding application of a domestic exemption from dividends to an Irish holding company. The judgment provides that the dividends paid by the Norwegian company to the
See MoreNetherlands: Updated decree publishes on implication of participation exemption
Decree No. BLKB2016/803M dated 20 January 2017 has been published in Official Gazette No. 5003 on 23 February 2017 regarding implication of the exemption from the participation. The Decree updated and replaced the Decree No. DGB2010/2154M of 12 July
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 MoreAustralia: Draft taxation ruling on timing for PE
On 12 October 2016, the Australian Taxation Office (ATO) released for comment Draft Taxation Ruling TR 2016/D2 that provides guidance on applying the participation test in Subdivision 768-A when working out whether an equity distribution received by
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 MoreCzech Republic: Income Tax Law amendment regarding participation exemption
The Senate has approved a bill on 6th April 2016 that introduces changes to the Income Tax Law. The bill must be signed into law by the President for becoming law. It has been predicted that the bill will be applicable the first day of the calendar
See MoreDenmark proposes amendments for the several laws
The Ministry of Taxation submitted a law proposal (L 123) to the parliament on 23 February 2016, amending several laws. The proposal includes the following amendments: Participation exemption: -The rules on the participation exemption are enhanced
See MoreFrance: Abolition of add-back on dividends within tax-consolidated groups
An amendment was adopted by the National Assembly on 2 December 2015 to abolish the neutralization within tax consolidated groups of the 5% add-back on dividends qualifying for the participation exemption. The add-back will therefore be reduced to
See MoreSlovenia: Changes to corporate income tax law enter into force
The amendments to the Corporate Income Tax Law were published on 3 November 2015, in the Official Gazette No. 83/2015. The Law entered into force on 4 November 2015. The amendments to the Corporate Income Tax Law include: - Implementation of
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
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