New Russian CFC and anti-avoidance legislation
The amended draft law regarding controlled foreign companies and other anti-offshore measures has done most valuable changes in the field of foreign tax structures and tax avoidance. This law has publicly available on 27 May, 2014. It highlights
See MoreUS: Study Moves to Curb State Corporate Tax Incentives
The Council on Foreign Relations (CFR) in the US has recently published a memorandum that looks at the tax relief and subsidies the US federal and state governments grant every year as an incentive to attract business investment. The memorandum
See MoreTaiwan Approves 45 Percent Top Income Tax Rate
Tax reforms passed in Taiwan include a 45% rate of income tax on incomes above TWD 10 million per annum. Also included in the reform is an increase in the basic income tax threshold to TWD 90,000 for single taxpayers and TWD 180,000 for married
See MoreNorway: Regulations regarding exemptions to the interest
On 24 April 2014, Norway’s Ministry of Finance issued regulations regarding exemptions to the interest deduction limitation rules. Under regulations issued in April 2014 certain securities transactions are exempt from the interest restriction
See MoreChina: Issues circular to clarify corporate income tax incentive
On 25 March 2014, China’s Ministry of Finance and State Administration of Taxation (SAT) jointly issued a circular, Caishui No. 26 (Circular 26) to clarify the criteria for the 15% preferential corporate income tax (CIT). A lower 15% incentive
See MoreGerman States Agree Tougher Tax Regularization Rules
German federal state finance ministers have discussed improvements to the tax system and have decided on action to strengthen the “declaration of non-compliance” that permits residents to regularize their tax affairs without the possibility of
See MoreFrench Local Tax Reforms Have Cut Tax Burden
A report issued by the Board of Compulsory Levies (CPO) in France suggests that small and medium enterprises have benefited by the introduction of the local economic contribution in place of the local business tax. This contribution is the most
See MoreBrazil: Superior Court Rules in Vale CFC Appeal
The Superior Court of Justice in Brazil has arrived at a decision in relation to the mining company Vale. The Court has ruled that profits of Controlled Foreign Companies (CFCs) of Vale in Belgium, Luxembourg, and Denmark would not give rise to a
See MoreUK: Tax Reform Has Boosted UK’s Appeal to Business
The UK’s Exchequer Secretary has suggested that there is currently high business confidence in the tax system. One reason for this is that the UK has recently taken measures to improve the attractiveness of its tax system including reductions to
See MoreSwiss Bankers Ask France to Increase Amnesty Uptake
The President of the Swiss Bankers Association (SBA), has suggested that France should extend and enhance its tax regularization facility to allow more taxpayers to make a voluntary declaration to normalize their tax affairs. At the moment the
See MoreJapan Planning Corporate Tax Cut Next Year
There are plans to lower the corporate tax rate following the work of the Tax Commission appointed by the Japanese government. The Commission suggested an eventual reduction of the corporate tax rate to around 25 percent, and the Deputy Economy
See MoreGermany: Draft guidance amending corporate tax loss limitation rules
Germany has issued draft guidance to replace prior advice on the corporate tax loss limitation rules. The current guidance was issued in 2008 and although there have not been any changes to the basic provisions in this area the new guidance aims to
See MoreAutomatic exchange of tax information between G5 and partners will begin in 2017
The finance ministers of the five largest economies of Europe committed last year to arrange for the automatic exchange of tax information between them. The ministers have now confirmed that the implementation of this project is to commence from
See MoreSingapore – GST rules affecting funds management industry
The Inland Revenue Authority of Singapore (IRAS) and the Monetary Authority of Singapore have finalized a set of rules relating to the impact of the goods and services tax (GST) on the funds management industry. Rules are laid down to establish the
See MoreSingapore – Finding of tax avoidance arrangement upheld on appeal
In Singapore a decision of the High Court on a tax avoidance arrangement has been upheld by the Court of Appeal. Although the taxpayer had made an arrangement to avoid tax the Court found that the Comptroller had acted beyond the powers bestowed by
See MoreMexico – Transfer pricing implications of pro-rata expense decision
A recent decision from Mexico’s Supreme Court of Justice declared a provision of the tax law to be unconstitutional. The provision related to pro-rata expenses incurred abroad relating to natural or legal persons that are not Mexican taxpayers.
See MoreRomania: Announces tax reforms
Romania is introducing a tax exemption on reinvested profit as part of an emergency ordinance. The tax exemption is to apply from 1 July 2014 and is to continue until the end of 2015. This is intended to encourage more investment in new assets in an
See MoreColombia: issues regulations on thin capitalization provisions
The Colombian government issued Decree 627 on 26 March 2014. This Decree regulates the thin capitalization rules (article 118-1 of the Tax Code) that were brought in as part of the recent tax reforms and takes effect from the date of publication.
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