Colombia: Key changes on international mergers and spin-offs
According to a recently published Ruling 2242 of 2017, the Colombian National Tax Authority (DIAN) pronounced on the tax effects of international mergers and spin-offs. In accordance with article 319-8 of the Tax Code (TC), the transfer of assets
See MoreRussia: Simplified expense deduction for corporate income tax purposes
The Federal Tax Service on 21 February 2017, explained the deduction of expenses for Corporate Income Tax (CIT) purposes. Accordingly, a taxpayer may deduct expenses from corporate income in the tax period in which they are incurred, regardless of
See MoreCyprus: Cyprus: Tax Authority abolishes minimum margins on loans effective from 1 July 2017
The Cypriot Tax Authorities (CTA) has announced their intention of withdrawing the Minimum Margin scheme (the MMS) with effect 1 July 2017. It is being reminded that in accordance with Article 33 of the Cyprus Income Tax Law, all transactions
See MoreUkraine: Amendments to tax code effective from 1 January 2017
The amendments to the Tax Code have been effective, with some exceptions, since 1 January 2017. Below is a summary of the most significant changes in corporate profit tax and transfer pricing. Corporate profit tax: The general tax rate remains
See MoreOman: Key changes to income tax law
On 26 February 2017, the Oman Government has passed a Royal Decree 9/2017 in the Official Gazette with a number of significant changes to Income Tax Law 2010. The major changes passed by the Royal Decree are following: An increase in the
See MoreGreece: Submission of aggregate customer statements of voluntary disclosure releases
The Public Revenue Authority has published a document ΔΠΦΥ Β 1018794 ΕΞ 2017 on 7th February 2017 that provides clarifications on the submission of aggregate customer statements by suppliers and traders contained by the framework of the
See MoreBrunei: MoF launches Income Tax Board of Review
The Ministry of Finance (MoF) announced the establishment of the Income Tax Board of Review, on 14 February 2017. The establishment aims to facilitate the administration and operation of taxation in Brunei Darussalam. The Income Tax Board of Review
See MoreSouth Africa: Finance Minister presents the Budget for 2017-2018
The Finance Minister of South Africa presented the Budget for 2017-18 to the Parliament on 22 February 2017. The main tax proposals of the Budget are given below. The 2017/18 tax year sees the introduction of a new top marginal income tax bracket
See MoreDTA between Russia and Spain: Russia clarifies taxation of dividends paid to non-resident
The Russian Ministry of Finance (MoF) on 22 February 2017, issued Guidance Letter No. 03-08-05/73316 of 7 December 2016, clarifying the taxation under the Russia - Spain Income and Capital Tax Treaty of the dividends derived by a Spanish
See MoreNetherlands: Updated decree publishes on implication of participation exemption
Decree No. BLKB2016/803M dated 20 January 2017 has been published in Official Gazette No. 5003 on 23 February 2017 regarding implication of the exemption from the participation. The Decree updated and replaced the Decree No. DGB2010/2154M of 12 July
See MoreColombia: Updated forms for filing tax returns in 2017
According to Administrative Regulation 6 of 2017, the National Tax Authority (DIAN) recently published the following forms for filing tax returns in 2017: Form 120: informative transfer pricing return; Form 140: CREE tax return; Form 160:
See MoreColombia: New deadlines for filing tax returns
Decree 220 of 2017 amends Decree 1625 of 2016 regarding the deadlines for filing tax returns. In the case of large-income taxpayers, the Decree provides the deadlines to pay their income tax corresponding to tax year 2016 in three installments. It
See MoreJapan: Tax treatment of income from U.S. limited partnerships is treated as fiscally transparent entity
On 9 February 2017, Japan’s National Tax Agency (NTA) released a report on its website confirming that a US limited partnership (US LP) is treated as fiscally transparent for Japanese tax purposes when applying the US-Japan Income Tax Treaty. The
See MoreAngola: Tax provisions released in Budget Law 2017
The budget law 2017 was officially made available to the public on 10th February 2017. The budget law was approved by the National Assembly on 17 November 2017 and was enacted on 31 December 2016. According to Budget Law 2017, the 10% withholding
See MoreChile: Tax Administration replies first query regarding GAAR
The Tax Administration has released Administrative Jurisprudence No. 261/2017 on 3rd February 2017 on its website. This addresses for the first time a query regarding the application or non-application of the general anti-avoidance rule (GAAR)
See MoreSwitzerland: Tax Administration announces safe harbor inter-company interest rates for 2017
The Swiss Federal Tax Administration (SFTA) published safe harbor interest rates on intra-group loans in Swiss Franc as well as in foreign currencies. On 13 February 2017, SFTA released a circular in relation to safe haven interest rates. According
See MoreAustria: Updated the guidance on tax incentives for start-up companies
The Ministry of Finance updated guidance on tax incentives for start-up companies on 14 February 2017. The incentives for start-up companies are granted if the following requirements are met: A new company has been set up; The company derives
See MoreTurkey: Possibility of R&D and designing expenses deduction boosted
The regulation regarding the implementation and control of R&D and designing support was published in the Official Gazette on 14th February 2017, which amends the previous regulation. The Regulation boosts the opportunity of expenses incurred by
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