South 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 MoreUnited Kingdom: Dispute resolution, CFC financing, investment “white list”
HM Revenue & Customs have updated some key documents regarding resolution of tax disputes, and have provided new guidance on CFCs. The dispute resolution documents are the Code of Governance for resolving tax disputes; and Commentary on the
See MoreItaly: Financial Transaction Tax (FTT) annual return model published
The Italian tax administration has issued the final Financial Transaction Tax (FTT) annual return model and the related instructions under Protocol No. 2013/154577. The FTT return should be filed by 31 March of every year, subject to a de minimis
See MoreUruguay: Tax penalties increased
Decree No. 402/013, was published in the Official Journal (Diario Oficial No. 28,870) on 23 December 2013. This increased the penalties on tax infringements and such penalties applicable as from 1 January 2014 will range from a minimum of UYU290 to
See MoreVietnam: Decree on tax penalties
Vietnam has released a new Decree on 16 October 2013 on tax penalties along with the amended law on Tax Administration, which specifies tax administrative procedures. The Decree becomes effective on 15 December 2013 and applies to any violations
See MoreItaly: Efforts to combat tax evasion
Italy has taken steps to discourage cash payment for certain goods and services from 1 January 2014 as part of the effort to combat tax evasion. E.g. claims for the additional tax deduction for reconstruction or energy-saving work will be denied for
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