Ghana: New Income Tax Act from January 2016
Ghana's new Income Tax Act (No. 896 of 2015) will come into force on January 1, 2016. It is intended to improve tax compliance and administration and broaden the country's income tax base by rationalizing tax breaks. A number of significant changes
See MoreRussia: MoF clarifies interest expense regarding loans
The Ministry of Finance (MoF) has recently released Letter No. 03-03-06/1/63388 to clarify the applicable tax treatment of interest expense incurred on a loan used to pay dividends. According to Article 252 of the Tax Code (TC) a taxpayer may
See MoreSri Lanka: Tax proposals in National Budget 2016
The Finance Minister of Sri Lanka has presented the national budget 2016 on 20 November 2015. The Budget includes some changes related to the corporate income tax rate structure, several tax incentives for selected industries, the Economic Service
See MoreNigeria: Implications of BEPS proposals
The Federal Inland Revenue Service (FIRS) has incorporated into its tax audit procedures certain of the recommendations included in the OECD’s base erosion and profit shifting (BEPS) project. For instance, the tax authority is scrutinizing
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 MoreIndonesia: Issued Regulation on Fixed Assets Revaluation
The Ministry of Finance (MoF) issued Regulation No. 191/PMK.010/2015 (PMK-191) on the revaluation of fixed assets in order to assist taxpayers when the thin capitalization rules are implemented).This regulation is applicable to those companies that
See MoreUkraine: Draft law proposed to introduce thin capitalization rules
Draft law No. 3357 on amending the Tax Code of Ukraine regarding tax liberalization was registered in the Ukrainian parliament on October 26, 2015. The draft law have proposed several tax measure including thin capitalization rules and distributed
See MoreSlovak Republic: Concept of ‘company in crisis’ in introduced into Commercial Code
The amendment to the Slovakian Commercial Code introduces the concept of a “company in crisis”. It will be effective from 1st January 2016. A company is regarded ‘in crisis’ if it is: Bankrupt; or The share of its equity and
See MoreIndia Publishes Notification on Use of Arm’s Length Range and Multiple Year Data
Recently, the Central Board of Direct Taxes published 'Notification No. 83/2015' of 19 October 2015 revising the Income-tax Rules, 1962 in relation to the use of range and multiple year data. The Notification amends Rule 10B and introduces Rule
See MoreRussia: A draft order regarding tax exchange information published
The Federal Tax Service (FTS) has released a draft order on 26th October 2015 that contains a list (in Russian) of countries and territories which do not exchange tax information with Russia for discussion purposes. According to article 25.13-1 of
See MoreItaly: Published Legislative Decree to Implement Tax Measures
Italy has Published Legislative Decree No. 147 of 14 September 2015 to Implement Tax Measures. The following issues are the main corporate tax measures as per the Legislative Decree: As per article 3 of the Legislative Decree, Dividends directly
See MoreItaly: Published Legislative Decree on Transfer Pricing Issues in the Official Gazette
Italy Published Legislative decree n. 147 in the official gazette on 22 September 2015 with a view to provide investors with certainty arising from their investment plan. As per the published Legislative decree, expenses relating to the transactions
See MoreUS: IRS Released Temporary Regulations to Clarify that the Arm’s-Length Standard of Section 482 Applies to all Controlled Transactions
IRS issued Treasury Decision 9738 on 14 September 2015 containing temporary regulations under Section 482 clarifying the application of the arm’s-length standard when multiple code sections. The temporary regulations apply to tax years ending on
See MorePolish parliament approves new transfer pricing rules
The parliament approved a bill on 11 September 2015 including changes the transfer pricing rules regarding transactions between related parties. According to the bill a taxpayer that is part of a multinational corporate group with annual income or
See MoreIndia: No related-party relationship, despite substantial single-party purchases
In the case of: DCIT v. W.B. Engineers International Pvt. Ltd. (ITA No. 523/PN/2014, The Pune Bench of the Income-tax Appellate Tribunal upheld the findings of the Dispute Resolution Panel that because a taxpayer merely hold substantial
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 MoreCosta Rica Introduces arm’s length price principle
The Bill No. 19,679 dated 12 August 2015 was submitted to the Legislative Assembly to introduce the arm's length principle to further develop the transfer pricing rules via regulations. The Bill No. 19,679 dated 12 August 2015 was submitted to the
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
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