Russia-Applicable fields for applying thin capitalization rules
The Ministry of Finance has published Letter No. 03-08-05/23521 regarding the applicability of the thin capitalization rules to interest payments made by a Russian company on a loan granted by a Russian bank issued on June 21, 2013. For example, a
See MoreIndia: Determines arm’s length price of share transfers
The Income-tax Appellate Tribunal has held that the discounted cash flow method was preferable over the “yield” method or “net asset value” method for purposes of determining the arm’s length price of shares transferred to related parties.
See MoreSwitzerland: Tax burden remain stable in 2014
According to a media report, the Swiss Federal Department of Finance has issued its tax exploitation index for 2014 on 10 December 2013; it disclosed that the average tax burden in Switzerland will remain same in 2014, compared to 2013. On average,
See MoreCanada -Partnership information return for 2013
The Canadian Revenue Agency (CRA) has issued revised guidance for partnership information returns (Guide T4068), Guide for the Partnership Information Return (T5013 Forms) for the year 2013. The Guide T4068 contains changes to the forms, schedules
See MoreCanada – Making Declaration of proposed tax changes in Ontario
The Finance Ministry in Ontario has declared proposed measures to increase the tax rate on “non-eligible dividends” of up to 3.9% which was effective from January 1, 2014. Other proposed measures would include: Certain research and development
See MoreBelgium confirms withholding tax rate changes
Belgium has decided to reduce the rate of withholding tax levied on small- and medium-sized enterprise (SME) dividends from 25 percent to 15 percent; and it is a confirmation from The Belgian Prime Minister. In order to encourage entrepreneurs to
See MoreRussia- Court rules for establishing thin capitalization to a sister company loan
Russia’s Federal Arbitration Court of the North-West region has issued Ruling No. А52-4072/2012 on September 18, 2013 concerning the establishment by a sister company of thin capitalization rules to a loan issued. Russian court practice already
See MoreJapan – Early repeal of special reconstruction corporation tax
The Japanese government has announced an economic stimulus package that includes a statement that “special reconstruction corporation tax (i.e., a 10% additional tax imposed on corporation tax liability) would be repealed a year earlier than
See MoreUS: District of Columbia Introduces Prepaid Card Option For Tax Refunds
The District of Columbia Office of Tax and Revenue (OTR) has announced a new option taxpayers can choose to receive their local income tax refunds. Beginning next year, a prepaid card will be available as an alternative to paper checks and direct
See MoreUnited Kingdom: UK High Court decision on portfolio dividend tax
UK High Court decision concerns the portfolio dividend tax (holdings of less than 10%) under the previous tax law which provided double tax relief for foreign withholding taxes paid on the dividends and no relief for any underlying tax. UK has moved
See MoreIreland: Opportunities to claim R&D tax credits
It is clear that in Ireland the research and development tax credit is not limited to research in the laboratory. A company may consider the day to day activity like developing a new product, devising or making improvements to a production process,
See MoreFrench Assembly Passes Tax Evasion Bill
The French National Assembly has definitively adopted the Government's anti-tax evasion and major economic and financial crime bill. The legislation was passed by 358 votes to 198. The bill is designed to considerably strengthen the capacities of
See MoreCanada –New Form due to research expenses
The Revenue Agency of Canada has released a revised version of Form T661 naming Scientific Research and Experimental Development (SR&ED) Expenditures Claim. The legislative changes proposed in the 2013 and 2012 federal budgets are addressed in
See MoreBulgaria releases tax withheld on specific EU traded bond interest
The Bulgarian Corporate Income Tax Act amendments will take into effect on January 1, 2014. No tax at source will be deducted on interest from bonds or other debt instruments issued by a Bulgarian entity and traded on an EU regulated market,
See MoreCanada: Deduction of R&D tax credit rate starting from 2014
The normal rate for tax credits under the federal government’s scientific research and experimental development (SR&ED) program will be deducted from 20% to 15% starting in 2014. For claiming SR&ED tax credits during 2014, Companies
See MoreSpain: Transactions exceeding €1 million need to report
Companies holding balances or conducting transactions during 2013 with foreign companies that exceed €1 million is required to report. This new reporting requirement impact companies in Spain as well as international multinational entities with
See MoreItaly: Duration of advance payment of income tax extends
The Government of Italy increased the advance income tax payment due for fiscal year 2013 and delayed the deadline for the payment of the second installment via Law Decree 133/2013 dated 30 November 2013. The increase of overall advance payment due
See MoreVietnam – Changes to tax administrative penalty rules
Vietnam’s tax authorities have issued a decree that amends the rules that apply with respect to penalties assessed for tax administrative violations. Decree 129/2013/ND-CP (16 October 2013) revises the tax administrative penalty rules. Among the
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