World Tax Brief : January & February 2015
Belgium Taxability of other income: From 2015 small and medium sized companies may create a "liquidation reserve" from after-tax profits. The liquidation reserve is immediately subject to a separate tax of 10%. Upon liquidation, no dividend
See MoreSpain: Government approves special tax regime for the Canary Islands
The Spanish Government has approved the agreement with the European Union (EU) Commission for the new Spanish special tax regime for the Canary Islands (Zona Especial Canaria, or ZEC ), which entered into force on January 1, 2015. The regime is
See MoreChile: Tax administration clarifies tax treatment of gains from exclusion of shares
Tax administration has issued Ruling 1016 of 14th April 2015 which explains the tax treatment of gains from the alienation of shares issued by joint-stock companies incorporated in Chile. Those gains are omitted from income tax, inter alia, under
See MoreUK: Main Rate of Corporation Tax Falls to 20% and is Unified
The main rate of Corporation Tax for 2015 is 20% (With the exception of oil and gas companies with ring fence profits) from 1 April 2015. The Corporation Tax will be charged at a single rate known as the main rate. The small profits rate was
See MoreTurkey: General Communique on corporate tax exemption released
The General Communique No. 8 regarding Corporate Income Tax has been published in the Official Gazette on 21st April 2015 and it changes General Communique No. 1 on Corporate Income Tax. This also gives information desired for the implementation of
See MorePoland: New thin capitalization rules
The thin capitalization rules changes in Poland and this rule enacted as an amendment to Poland’s corporate income tax law, and signed by the president on 17 September 2014 and from 1 January 2015 the “thin capitalization” rules has been
See MoreNamibia: Budget proposals for 2015-16
The Namibian budget speech for 2015-16 was delivered on 31 March 2015. In the budget it was proposed to reduce the corporate income tax rate for non-mining companies from 33% to 32%. There will be no change in the corporate tax rate for mining
See MoreFrance: Intergroup services marked out in tax-avoidance transactions list
The French tax administration has recently published an updated list of abusive practices and fixtures that are considered to be contrary to the law. Among these are certain inter-group arrangements. Relocation of profits after restructuring:
See MoreRussia: Law concerning notification process of CFCs adopted
The parliament has approved Law No. 667946-6 on 27th March 2015 for extending the deadline of tax resident’s notification about the involvements held in controlled foreign companies (CFCs). The deadline for notification has been extended from 1st
See MoreRussia: State Duma considers new draft law regarding thin capitalization rules
The Russian State Duma Council accepted the decision on 17th February 2015 to incorporate a new draft of Law No. 724609-6 on the introduction of changes to Article 269, Part 2 of the Tax Code regarding the meaning of controlled debt. The draft law
See MoreUK Issues Guidance on the Diverted Profits Tax
The UK included legislation to introduce the Diverted Profits Tax in the Finance Bill for 2015. Guidance on the tax was updated on 30 March 2015 to explain the changes to the provisions since the draft legislation was first published. The guidance
See MoreRussia: Application for participation exemption by a tax agent
The Finance Ministry (MoF) has issued Letter No. 03-03-06/1/885 on 19th January 2015 for describing the application of the participation exemption by a tax agent giving dividends to a Russian company. In accordance with article 284 (3) of the Tax
See MoreVietnam: Releases Decree on Tax administration
Decree No. 12/2015/ND-CP (Decree 12), on the implementation of Law No. 71/2014/QH13 was issued on 12 February 2015 and which is effective from 1 January 2015. The main changes regarding tax administration are summarized below: Supporting documents
See MoreEgypt: Rules for Dividend taxation, electronic tax payments
In Egypt, there are rules for the taxation of dividends and requirements for electronic tax payments by joint-stock companies and state-owned entities. Dividend tax for corporate entities: For corporate entities, the dividend tax applies at a rate
See MoreUK: Proposes new measures to tackle tax evaders
The UK has announced new measures to deal with tax evasion. The proposed measures are outlined in a policy paper issued on 19 March 2015 entitled “Tackling tax evasion and avoidance”. The UK government is introducing measures including publicly
See MoreTaiwan: Amendments to Transfer Pricing Rules
The Ministry of Finance announced on 6 March 2015 amendments to the transfer pricing rules governing non-arm’s length transactions of profit-seeking enterprises. This amendment coming 10 years after the promulgation of the transfer pricing
See MoreUK: Budget Announcements for 2015/16
The UK budget announcements were delivered on 18 March 2015. The detail of the announcements is as follows: Business tax measures As already announced the UK corporation tax rate is 20% from 1 April 2015. The budget announcements include the
See MoreRussia: State Duma passes new tax law without extension of thin capitalization rules
The President has signed a new law on 8th March 2015 for changing article 269 of the Russian Tax Code. Precisely, the provisions of extending thin capitalization rules to foreign affiliates and bank loans are excluded from the new law. Under Russian
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