Singapore: Publishes E-Tax Guide on General anti-avoidance rule
The Inland Revenue Authority of Singapore (IRAS) issued an e-Tax Guide (the Guide) on 11 July 2016, clarifying the general anti-avoidance rule and its application. IRAS issues the Guide with the following purposes: -To explain IRAS's approach to
See MoreEU agrees on draft Directive on anti-avoidance
On 21 June 2016 the EU’s Economic and Financial Affairs Council reached agreement on a draft Directive on tax avoidance practices following expiry of the required period for further issues to be raised. The draft Directive will be presented for
See MoreChile: Law to simplify structural tax reform of 2014 published
Law No. 20.899 was published in the Official Gazette on 8th February 2016. This Law simplifies the implementation of the tax reform 2014 in matters regarding provisions of the tax code, income tax and VAT, among others. Under the tax reform of 2014
See MoreIMF Technical Note on introducing a GAAR
On 31 January 2016 the IMF issued a technical note on ensuring that a general anti-avoidance rule (GAAR) achieves its purpose. Many countries have either introduced a GAAR or are considering its introduction, which the objective of combating
See MoreColombia: Update rules on general anti-avoidance rule (GAAR)
The National Tax Authority of Colombia (DIAN) in a recently published Ruling no: 25473 of 2015, pronounced on the general anti-avoidance rule provided under article 869 of the Tax Code. In accordance with sub-paragraph 4 of article 869 of the Tax
See MoreAustralian Taxation Office releases GAAR guidelines
The Australian Taxation Office released for comment a draft practice statement PS LA 2005/24 which deals with the application of the general anti-avoidance rules (GAAR) in Part-IVA of the Income Tax Assessment Act 1936 on 13 August 2015. This Draft
See MoreChile: IRS issues guidelines regarding anti-avoidance rules
The Inland Revenue Service (IRS) in Chile has issued total 7 circulars including Circulars 65 and 68 on 23rd July 2015 for giving directions won the anti-avoidance rules enacted as part of Law No. 20780. The circulars contain limitations on the
See MoreChile: Bill to amend the tax reform of 2014
The Finance Ministry has declared that the Government submitted a bill on 10th August 2015 to amend the tax reform of 2014. The main features of the bill will be as follows: The combined income tax regime with income attribution would be
See MoreChina: SAT Regulates the Administration of the GAAR
Recently, the State Administration of Taxation (SAT) issued the Administrative Measures on the General Anti-Avoidance Rule (GAAR) to further regulate and clarify various matters, such as applicable scope, judging criteria, adjustment methods,
See MoreItaly: New anti-avoidance rules
The Italian Parliament approved the Law no. 23 of 2014 in March 2014 empowering the government to enact a partial reform of the Italian fiscal system. The government will adopt legislative decrees for the amendment of the Italian abuse of law and
See MoreVietnam releases circular on treaty benefit application
Recently, Vietnam issued Circular 205 providing rules on the applicability of tax treaty benefits and general anti-abuse provisions (GAAR) which will become effective 6 February 2014. The main changes in Circular 205 from the previous circular are
See MoreIndia – Implications of GAAR from 2015
Recently, in India general anti-avoidance rule (GAAR) has been introduced which will become effective from 1 April 2015 (Financial Year 2015-16). The rules for application of the GAAR provide certain exceptions which clarify that the GAAR will not
See MoreIndia: CBDT issues rules for application of GAAR
The government of India has allotted a General Anti Avoidance Rule (GAAR) in order to combat tax avoidance. The GAAR which was originally introduced in the 2012/13 budget will be effective from 1 April 2016. The Rules are applicable for tax years
See MoreGreece: Current transfer pricing legislation changes
Recently, major transfer pricing regulation changes have taken place in Greece. A bill was approved on 29 August 2013 by the Greek Parliament to expand the deadline for disclosing to the tax authority the inter-company transactions within a group
See MoreUK: Finance Act 2013 receives the Royal Assent
The 2013 Finance Act became law on 17 July 2013. The main provisions include a reduction of the corporate tax rate from 22% to 21% in 2014/15 and to 20% in 2015/16. The Act also includes the legislation introducing the General Anti Abuse Rule
See MoreUK: Terms of Reference issued for GAAR advisory panel
The legislation in respect of the General Anti Abuse Rule (GAAR) in the Finance Bill 2013 provides for the appointment of a GAAR advisory panel. The panel is to consider and approve HMRC’s guidance on the GAAR. It is also required to consider
See MoreAustralia: Proposal to amend GAAR
The Australian government on 13th February 2013 introduced Tax Laws Amendment Bill 2013. According to Tax Laws Amendment Bill 2013, companies will have to ensure that the commercial and other factors motivating a decision are properly documented.
See MoreIndia: General Anti-Avoidance Rule For 2014
The General Anti –Avoidance Rule (GAAR) of India had been scheduled to be implemented from April 2014. After further consultation the provisions will however now come into effect from April 1, 2016 and these provisions would be used to target only
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