Slovak Republic: Tax amendments for 2015 has approved by the Parliament
The Parliament of Slovak Republic has approved the proposed changes regarding the Income Tax Act on 30th October 2014 and it is to be in effect from 1st January 2015. The amendments are basically held on thin capitalization rules, local transfer
See MoreCourt decides that the provision of tax treaties between Germany & Russia do not obstruct the application of thin capitalization rules
The Federal Arbitration Court of the Moscow decides that the provision of tax treaties between Germany & Russia do not obstruct the application of thin capitalization rules. The Federal Arbitration Court of the Moscow Circuit (FAC) decided in
See MoreBrazil: Amendments on Controlled Foreign Corporations (CFC) Rules
A deemed tax credit of 9% under CFC rules for Brazilian companies with foreign investment in some predefined industrial sector has been extended by a recent guidance. The deemed tax credit results in the lower taxation of profits earned abroad by
See MoreChile: Law No. 20.780 has enacted with different aspects
A tax reform entitled “Law No. 20.780” related to foreign investor has published on 29 September 2014 which is effective from 1st October 2014. This creates different regimes subject to Corporate Income Tax (CIT) from 1st January 2017. The CIT
See MoreColombia: Court has ruled thin capitalization rule constitutional
The Constitutional Court of Colombia has ruled that the thin capitalization has been incorporated into the tax law by Article 109 of Law 1607 of 2012 and the rule is constitutional. The claimant raised the issue that the deductibility limit is
See MoreAustralia: Parliament changes thin capitalization rules
The Australian Parliament passed previously announced legislation on 25 September 2014 which includes changes to the thin capitalization rules, a rewrite of the exemption for foreign non-portfolio dividends received by Australian companies, and
See MoreRussia: Revised version of the draft law publishes
The Ministry of Finance in Russia has released a significantly revised version of the draft law on the package of tax initiatives on September 2, 2014. This contains a number of significant changes affecting such matters as exclusions from
See MoreSlovak Republic: Proposals on transfer pricing and thin capitalization
A draft amendment to income tax law in Slovakia contains provisions regarding changes to the rules for transfer pricing and thin capitalization. The amendment was accepted on August 2014, and if enacted, the changes usually would have an effective
See MoreSpain: Releases modified tax laws by the Spanish Government
On 23 June 2014, draft bills modifying the most important Spanish tax laws were released. The Spanish Government released the second draft bill on 1 August 2014, which will now be discussed and voted on by the Spanish Parliament. It is intended that
See MoreKorea-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
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