India – 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 MoreBrazil: Changes to transfer pricing regulations
Brazil issued Normative Instruction 1,395/2013 on 30 September 2013.This Instruction introduced changes to Normative Instruction 1,312/2012 regarding the prices that must be used in cross-border transactions involving the sale and purchase of goods,
See MoreAustralia: Liabilities classification for Thin Capitalization
As a consequence of changes to Australia’s thin capitalization rules taxpayers may need to review their thin capitalization position. Now every entity must have to consider whether their liabilities are debt or non-debt and the effect on the
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 MoreChile: Circular notifying transfer pricing changes
The Chilean Internal Revenue Service (IRS) has released Circular No. 29 on June 14, 2013 that includes instructions regarding the new transfer pricing rules introduced by Law 20,630. The circular recognizes the OECD TP Guidelines as a valid source
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 MoreIndia: Requirements For Transfer pricing’s “deemed international transaction”
India’s transfer pricing rules are designed to prevent the use of transfer prices between related enterprises to shift profits away from India to a lower tax jurisdiction. The rules are therefore generally concerned with international transactions
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 MoreKorea: Update on rules for application of arm’s length standard to head office–branch transactions
Korea’s Ministry of Strategy and Finance has issued new regulations to clarify the method for calculating domestic-source income from intra-company transactions between a foreign head office and its Korean branch. This follows the passing of the
See MorePoland – Changes to transfer pricing documentation, thin capitalization rules
Legislation to expand the scope of Poland’s corporate income tax law is intended to be effective in 2014. The provisions of the legislation released on February 18, 2013 include changes to the transfer pricing documentation and thin capitalization
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
See MoreImplementation of Malaysian thin capitalization has been deferred
The Ministry of Finance announced on 11 December 2012 that the implementation of the thin capitalization rules has been deferred until the end of December
See MoreIndonesia – Potential changes to the transfer pricing regulations
The Director General of Taxation of Indonesia has recently focused on transfer pricing, proposing some changes to the existing transfer pricing rules. However, these proposals are not yet final and some changes may be made before the final issuance
See MoreAustralia – Proposed amendments of transfer pricing rules
The Australian Assistant Treasurer has recently Tax Laws Amendment (Cross-Border Transfer Pricing) Bill 2013: Modernization of transfer pricing rules,in which changes to transfer pricing rules were proposed. The new law focuses mainly on
See MoreBrazil Provisional Measure 6272013 – CFC rules for resident individuals introduced
On 4 December 2013 it has been published that the Provisional Measure 627/2013 (PM 627/2013), introduced important changes to the Brazilian tax legislation. This was published in the Official Gazette of 12 November 2013. Among those changes, PM
See MoreUK Budget Delivers Tax Cuts
The UK has delivered a Budget that unashamedly backs businesses, slashing the top rate of personal income tax and accelerating corporate tax cuts. Currently charged at 50% on all income over GBP150, 000, from April, 2013 the rate will drop to
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