Brazil: 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See MoreGermany: Draft guidance amending corporate tax loss limitation rules
Germany has issued draft guidance to replace prior advice on the corporate tax loss limitation rules.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.
See MoreHong Kong: Raises air passenger security charge
Hong Kong’s Airport Authority has raised the passenger security charge with effect from June 1 2014. This charge is paid by each passenger departing from Hong Kong International Airport and is to be increased by 36 percent. This passenger security
See MoreVietnam – Tax Revenue Receipts Increase
In Vietnam the tax collections in the first three months of 2014 reached VND134 trillion (USD6.37bn). This amount is 16.5 percent more than in the same period in 2013, and represents the highest level of first-quarter revenue in the past three
See MoreUS : Persons holding PFIC stock through tax-exempt organizations or accounts will be exempt from Form 8621 filing requirements
In the US the definition of a shareholder for the purpose of the Section 1291 regulations has been amended by Notice 2014-28. Under this section a special tax and interest charge is levied on a US person has shares in a passive foreign investment
See MoreUS – More taxpayers e-filing from home computers
An internal report issued by the Treasury Inspector General for Tax Administration (TIGTA) indicates that more US taxpayers are using e-filing to submit their tax returns and that more tax refunds are being issued. By 7 March 2014 more than 90
See MoreUS: Annual study shows heavy tax compliance burdens
According to the US National Taxpayers Union (NTU) the US has lost billions of hours of productivity owing to the burden of compliance with the complex tax code. The NTU has computed the total cost of tax compliance at USD224.3bn a year. This
See MoreOECD official suggests alternatives to arm’s length standard may be needed
As part of the action plan on base erosion and profit shifting consideration is being given to ways to improve the transfer pricing rules. According to an official of the Organization for Economic Cooperation and Development (OECD), the arm’s
See MoreJapan – Corporate income tax rate reduction effective April 2014
Following the enactment of Japan’s 2014 tax reform a decrease of the effective corporate income tax rate is in force from April 2014. The fall in the effective tax rate is a result of the repeal of the special reconstruction surtax. This surtax
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