Chile: 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
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
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