Lithuania : Loss carry forward limitations, extended incentives and reduced VAT rates
Losses carry forward limitations: Beginning in 2014, the ability of corporations in Lithuania to carry forward tax losses, for corporate income tax purposes, is limited. In calculating their corporate income tax for 2014 and subsequent tax periods,
See MoreColombia – New form for reporting withholding tax information
Colombia’s tax administration has recently released a new form to be used to make monthly information reporting of withholding tax. Form 350 reflects changes from the prior version of the form. Changes contained in the new form include a
See MoreArgentina: Income tax changes relating to share transfers and dividends
Changes have been made in Argentina to the income tax treatment of securities, the transfer of shares and dividend distributions. On 7 February 2014, Decree 2334 was published in the official gazette. This Decree implements income tax changes as
See MoreColombia: Filing deadlines for large taxpayers
Colombia has issued Decree 214/2014, under which taxpayers qualifying as large taxpayers as of 31 January 2014 (previously, 31 December 2013) must file their income tax returns between 1 March 2014 and 24 April 2014 within the deadlines established
See MoreUnited Kingdom – Supreme Court addresses cross-border group losses
The UK Supreme Court on 19 February 2014 issued its judgment relating to three remaining issues in the Marks & Spencer case—i.e., the case addressing a cross-border group relief claims. The Court found that the conditions for the “no
See MoreSouth Africa: Tax Guide for South African Shareholders Revised
The South African Revenue Service (SARS) has issued a revised edition of its Tax Guide for Share Owners, which provides general guidance on the tax consequences of holding shares as trading stock compared to holding them as capital assets. The Guide
See MoreSpanish capital gains tax rules found to be discriminatory by Supreme Court
In a decision on 25 October 2013 in the Brambles France case (appeal No 1374/2011), Spain's Supreme Court ruled that the capital gains tax on non-residents may be discriminatory in some cases. The case involved a French company that sold its shares
See MoreRussia: Ministry of Finance clarifies the transfer pricing rules
The Ministry of Finance Letter No. 03-01-18/53941, issued on 10 December 2013, clarifies the rules to determine the income for controlled transactions purposes. The Ministry of Finance specified that transactions defined in article 105.14 of the Tax
See MoreTaiwan – Income tax exemption for royalties and technical service fees
Taiwan has introduced an amendment concerning the rules governing taxpayers (including foreign for-profit entities) that apply for an exemption from income tax on royalties and technical service fees related to the manufacturing, technical service,
See MoreChile changes foreign tax credit system
On 31 January 2014, the Chilean government published in the official Gazette Law 20.727, which makes changes to the country’s foreign tax credit (FTC) rules. The FTC amendments increase the availability of FTCs for indirectly owned foreign
See MoreSlovakia – Reduced corporate income tax rate
Slovakia’s Parliament has reduced the corporate income tax rate from 23% to 22% with effect from 1 January 2014. The reduced corporate income tax rate is effective for tax periods beginning after 31 December 2013. This change affects both the
See MoreColombia: Thin capitalization provision
Under the Decree 3027 of 27 December 2013, the thin capitalization provisions interest is fully deductible up to a debt to equity ratio of 3:1. This applies to domestic and foreign loans from related or unrelated
See MoreVietnam releases circular on treaty benefit application
Recently, Vietnam issued Circular 205 providing rules on the applicability of tax treaty benefits and general anti-abuse provisions (GAAR) which will become effective 6 February 2014. The main changes in Circular 205 from the previous circular are
See MoreNorway reduces corporate tax rate and enacts interest deductibility restrictions
On 13 December 2013, the newly proposed Norwegian interest deduction limitation rules were adopted by the Norwegian Parliament and the reduction of the corporate income tax rate from 28 to 27 % was adopted. The interest deduction limitation rules
See MoreNetherlands: New Decree on substance requirements enters into force
From 1 January 2014, a new Decree entered into force which codifies the existing administrative guidance on substance requirements for companies engaged in inter company financing and/or licensing activities. Now, Dutch companies that claim the
See MoreUnited States: Technology Industry Lobbies for expanded Research Tax Credit
TechAmerica, a technology industry group, has asked that the tax credit for research and development (R&D) should become permanent, and be refundable for small start-ups. The R&D credit expired on 31 December 2013; it had survived as a
See MoreJapan- Main corporate income tax rate
A reconstruction surcharge of 2.55% applied in 2013 but does not apply after 1 April 2014.The effective corporate tax rate taking into account the local enterprise tax and local inhabitant tax will therefore be reduced to 35.64% (previously 38.01%)
See MoreVietnam: Corporate income tax rate reductions and rule changes
The Vietnam corporate income tax rate will be reduced to 20% from 1 January 2016 (now 22%). For taxpayers with total revenue lower than VND 20 billion, the will be 17% effective 1 January 2016 (now 20% as of 1 July 2013). New guidelines published as
See More