India: Marketing & Sales Promotion Expenses Not International Transactions for Arm’s Length Standard
The Bangalore Bench of the Income-tax Appellate Tribunal held in the case of: Essilor India vt. Ltd. v. DCIT that advertising, marketing, and sales promotion expenses to promote brand value were incurred only for increasing the taxpayer’s sales,
See MoreRussia: Amendments to CFC rules entered into force
The president of Russia has signed Federal Law No. 32-FZ on February 15, 2016 that amends the СFC provisions. This Law has published on 15th February 2016 and will enter into force on 1st January 2017. For bank loans that will already be exempt
See MoreRussia: Amendment in thin capitalization rules passed
Federal Law No. 25-FZ amending the thin capitalization rules was passed by the Parliament on 15 February 2016. As per the amended thin capitalization rules, interest on loans from banks and Russian companies will not be subject to the thin
See MoreRussia: Amendments to CFC rules adopted by lower chamber
The lower chamber of the parliament has passed in the third reading the draft Federal Law No. 724609-6 amending the thin capitalization rules on 29th January 2016, which was submitted to the lower chamber of the parliament on 14th December 2015. It
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 MoreNigeria: Country-by-country reporting update
A Multilateral Competent Authority Agreement (MCAA) has been signed by Nigeria for executing the exchange of country-by-country (CbC) reports. This reports will include summary of income earned and tax paid, and the number of employees positioned by
See MoreChile: Details of administrative interpretation on CFC rules disclosed
The Circular 30 of the tax administration has been effected from January 1, 2016. It was published in the official gazette on May 14, 2015. The main features of the CFC rules are as follows: A controlled foreign entity exists where a Chilean
See MoreMalaysia: Thin capitalization rules deferred till 2018
The Ministry of Finance has issued a noticed on 30 December, 2015, regarding the effective date of the Income Tax (Thin Capitalization) Rules. The Rules has been deferred to till 2018 and will take effect from 1 January
See MoreRussia: Draft amendments to CFC rules
A draft of Federal Law No. 953192-6 regarding the СFC provisions was submitted to the lower chamber of the parliament on 14th December 2015. The CFC provisions were first provided by the Tax Code and Federal Law No. 376-FZ of 24 November 2014. The
See MoreMexico-Publishes new Income Tax Law regulations regarding corporate taxation
The new regulations to the Income Tax Law were published in the Official Gazette on 8 October 2015. The main changes included in the regulations are summarized below: Corporate taxation: - Informative returns must be filed for donations exceeding
See MoreGhana: 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
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