Pakistan: Foreign tax registration documents mandatory for non-resident companies
The Federal Board of Revenue (FBR) has proposed to make it mandatory for non-resident companies with or without a permanent establishment (PE) in Pakistan to be registered for tax purposes and to provide their company and business details (including
See MoreRomania: Significant changes brought by the New Fiscal Code
The New Fiscal Code entered into force in Romania on 1 January 2016 addressing important changes in tax area. The New Tax Code introduced the definition of place of effective management, which represents the place where strategic decisions for the
See MoreDenmark proposes amendments for the several laws
The Ministry of Taxation submitted a law proposal (L 123) to the parliament on 23 February 2016, amending several laws. The proposal includes the following amendments: Participation exemption: -The rules on the participation exemption are enhanced
See MoreIndia: CBDT issues draft guidelines for determination of a company’s place of effective management
India's Central Board of Direct Taxes (CBDT) has issued draft guiding principles for determining if a company is a resident in India or has its place of effective management in India. The Finance Act 2015 amended the provisions of section 6(3) of
See MoreNigeria: Federal High Court reversed a decision regarding companies fixed base
The Federal High Court has reversed a decision of the Tax Appeal Tribunal in a case concerning if a corporation had a fixed base in Nigeria and concluded that the foreign corporation did not have a fixed base in Nigeria and was not responsible for
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 MoreMauritius: Signing of MOU with South Africa
South Africa and Mauritius have signed a memorandum of understanding (MOU) on 22 May 2015. Following the signature of the MOU the revised Double Taxation Agreement between the two countries is expected to become effective from 1 January 2016. To
See MoreChina: SAT Standardizes the CIT Administration of Indirect Transfer of Taxable Properties in China by Non-Tax Resident Enterprises (Non-TREs)
Since the ‘Economic Reform and Opening up’, China has maintained an ongoing economic boom which has resulted in the accumulation of a considerable amount of wealth in the value of immovable properties, equity investments and other properties.
See MoreHong Kong: IRD Releases Revised Forms To Apply For Resident Status For Tax Treaties
The Inland Revenue Board of Hong Kong on January 29 released revised forms for companies, partnership, trusts, and other entities to apply for a certificate of resident status for purposes of claiming tax treaty benefits. With effect from 1 February
See MoreOECD holds public consultation on preventing the artificial avoidance of PE status
On 21 January 2015 the OECD held a public consultation on the artificial avoidance of permanent establishment (PE) status. This is action 7 of the action plan on base erosion and profit shifting (BEPS). The OECD Model tax treaty permits the host
See MoreOECD publishes comments on prevention of artificial avoidance of PE status
On 13 January 2015 the OECD published on its website the comments received from interested parties on the discussion draft in respect of Action 7 of the action plan on base erosion and profit shifting (BEPS). This concerns prevention of artificial
See MoreThe Finance Ministry clarifies income allocation and expenses to Russian PE
The Finance Ministry (MoF) has published a Letter No. 52359 for describing the allocation of income and expenses to a Permanent Establishment (PE) in Russia of a non-resident company and it has issued on 17th October 2014. In accordance with article
See MoreCyprus – Company incorporated, but not tax resident of Cyprus
Circular 2014/3 of March 2014 gives guidance in respect of the tax return requirements in the situation where a company is incorporated in Cyprus but is not tax resident in the country. According to the Circular companies in this position must be
See MoreNew Zealand: New rules for determining tax residence
In New Zealand the Inland Revenue Department has issued an “interpretation statement” on tax residence. This is an update to previous guidance from 1989. The new statement takes effect from 1 April 2014 and includes residence criteria for
See MoreItalian Supreme Court rules on tax residence concept
The Italian Supreme Court gave its decision on 17 January 2014 in case No. 1811 concerning the issue of whether the Maltese company should be considered resident in Italy for tax purposes. The case particularly concerned the provision that a company
See MoreUruguay – Taxation procedure of public companies transferred to foreign country
An advisory firm of Uruguay recently issued a report concerning the transfer of public companies to a foreign country (and vice-versa). Generally those companies are no longer subject to Uruguay’s corporate income tax (since the company is no
See MoreChina: Taxable presence of foreign entity’s seconded workers
Recently a guidance concerning when the cross-border secondment of expatriate workers by foreign enterprises into China may give rise to a taxable presence in China is issued by the China’s State Administration of Taxation. Factors taken into
See MoreUK: Google under Fire for UK Tax liability
It has been published on 14 August 2012 that Google bosses could be hauled before the UK parliament to answer questions on the technology giant's tax affairs, as concerns mount over revelations about the company's low corporate tax bills. According
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