Korea-Tax Reform Proposals for 2015
The Ministry of Strategy and Finance of Korea announced the Tax Reform Proposals for 2015 on 6 August 2014. According to the proposals a new corporate accumulated earnings tax will be levied on excess cash of large corporations with equity capital
See MorePoland: Strengthen the thin capitalization rules
The Lower House of Parliament adopted the amended final version of thin capitalization rules after approval by the Higher House of Parliament on 29 August 2014 and it is very likely new legislation will enter into force from 1 January 2015. This
See MoreSouth Korea- Tighten Thin Capitalization Rules
Under revised thin capitalization rules of South Korea proposed for 2015, overseas multinational companies performing business would have to pay a higher tax. The existing thin capitalization rules reject the South Korean unit of a foreign
See MoreChile: Amendments in tax bill propose new corporate tax system
The Government has published a bill to adjust the proposals in the original tax reform legislation. The amendments to the tax reform bill are given below: A new corporate income tax system would build under which taxpayers could be able to choose
See MoreAustralia – Reduces safe harbor for thin capitalization
Australia recently reduced the safe harbor rule for thin capitalization limit from 75% to 60%, corporate groups may want to consider what steps to take with respect to their thin capitalization positions. With effect from 1 July 2014 the permitted
See MoreCzech Republic: Obligatory reporting on related-party transactions
The Czech Tax Administration has declared a new reporting obligation for all entities accountable for corporate income tax in the Czech Republic who has dealings with related parties. Czech taxpayers will have to file a separate disclosure form
See MoreRussia: Revised draft changes related to introduction of CFC rules
The Ministry of Finance has released a revised version of the draft law regarding introduction of CFC rules. The important changes of the revised draft law are given below: • Concepts regarding “Beneficial owner” and “actual right to receive
See MoreIndia: Introduces new rules aim to reduce transfer pricing tax disputes
The government of India introduced new tax rules with their new budget target to reducing litigation with multinational firms over cross-border transactions the government considers tax avoidance schemes. Now days, transfer pricing is an application
See MoreSlovak Republic: New improvements in Transfer Pricing
The Financial Directorate in Slovak Republic has issued a methodological guideline on the application of transfer pricing methods. According to the changes to the OECD Transfer Pricing Guidelines in July 2010, the amendment to the ITA has abolished
See MoreTanzania: regulations on transfer pricing released
The Transfer Pricing Regulations in Tanzania has finally been released through Government Notice No. 27 of 2014 and which is effective from 7 February 2014. The Income Tax Act 2004 already had a requirement in section 33 to transact between
See MorePoland: Proposals for CFC regime
Poland proposed bills to changes to its controlled foreign corporation (CFC) rules and thin capitalization regime. According to the rules tax would be levied on specific income which obtained from some foreign subsidiaries owned by the taxpayers of
See MoreRussia: Applicability of thin capitalization rules under certain conditions
The Ministry of Finance has issued Letter No. 03-08-05/9669 on May 6, 2014 that clarifies the application of thin capitalization rules to the interest paid by a Russian company (borrower) to another Russian company (lender) under a controlled loan
See MoreSlovak Republic: Thin capitalization rules has considered related-party debt
The Ministry of Finance is currently considering the chance of re-initiating thin capitalization rules into Slovak tax law. With the help of an internal document the Ministry of Finance highlights that low capitalization expresses an effective tax
See MoreAngola introduced transfer pricing rules
Angola introduced a transfer pricing rule with a Presidential Decree n. 14713 on June 2014. According to the decree, the taxpayers require to submit transfer pricing documentation by the end of June 2014 to the tax management for the 2013 tax year.
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 MoreNew Russian CFC and anti-avoidance legislation
The amended draft law regarding controlled foreign companies and other anti-offshore measures has done most valuable changes in the field of foreign tax structures and tax avoidance. This law has publicly available on 27 May, 2014. It highlights
See MoreMexico – Transfer pricing implications of pro-rata expense decision
A recent decision from Mexico’s Supreme Court of Justice declared a provision of the tax law to be unconstitutional. The provision related to pro-rata expenses incurred abroad relating to natural or legal persons that are not Mexican taxpayers.
See MoreColombia: issues regulations on thin capitalization provisions
The Colombian government issued Decree 627 on 26 March 2014. This Decree regulates the thin capitalization rules (article 118-1 of the Tax Code) that were brought in as part of the recent tax reforms and takes effect from the date of publication.
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