Brazil: Procedure to file requests for tax consultations
Brazil issued Normative Instruction 1,396/2013 on 30 September 2013.This Instruction regulates the administrative procedure to consult the federal tax authority on the interpretation of the tax and customs legislation concerning taxes administered
See MoreBrazil: Tax authority has issued ruling on tax treatment
The Federal Tax Authority issued Ruling No. 58/2013 on 27 August 2013, published in the Official Gazette on 30 August 2013, concerning the tax treatment of amounts deposited into escrow accounts associated with specific conditioned
See MoreBrazil: Changes to transfer pricing regulations
Brazil issued Normative Instruction 1,395/2013 on 30 September 2013.This Instruction introduced changes to Normative Instruction 1,312/2012 regarding the prices that must be used in cross-border transactions involving the sale and purchase of goods,
See MoreUruguay – Taxation procedure of public companies transferred to foreign country
An advisory firm of Uruguay recently issued a report concerning the transfer of public companies to a foreign country (and vice-versa). Generally those companies are no longer subject to Uruguay’s corporate income tax (since the company is no
See MoreCanada – Evaluation of GST/HST information
The Canadian Revenue Agency has began to judge the “hefty penalties” regarding the GST/HST annual information return that many large businesses and financial institutions in Canada are needed to report. The penalties (which can be as high as
See MoreUK: Judicial decisions on capital allowances
The Upper Tribunal rejected an appeal from HMRC against a capital allowance claim in a recent decision involving Lloyds TSB Equipment Leasing. The claim related to finance leases in relation to two liquid natural gas (LNG) vessels that were leased
See MoreChanges in e-Filing Tax Payments in South Africa
E-filing on debt pull transactions will be eliminated from September 4. The SARS disclosed that the procedure will take place over one month after an alert message will appear on e-filing, where a debt pulls transactions is no longer available.
See MoreBelgium: Notional interest deduction rate
June 2013 Legislation modifies the method which is used to calculate and determine the rate of the notional interest deduction. On the basis of the average return of the 10-year government bond (OLO) in the months July, August and September it is
See MoreBelgium – Clamping down on tax evasion and tax fraud
There has recently been concern internationally about tax evasion and fraud, and many countries have increased their efforts to trace income of their residents that has been illegally concealed in tax havens in an attempt to evade taxes. As a result
See MoreNew Zealand: Taking Tough Stance on Tax Avoidance
A former businessman has been punished recently over a total of 87 tax-related charges, and the Inland Revenue Department of New Zealand has warned that it will continue with its “zero tolerance” approach to tax evasion. This approach to
See MoreFrance: List of non-cooperative states or territories updated for 2013
The French government published a Ministerial Decree on 28 August 2013 updating the list of non-cooperative states or territories (NCSTs). The list will become effective from 1 January 2013. A major consequence for a country that is on the list of
See MoreAustralia: Liabilities classification for Thin Capitalization
As a consequence of changes to Australia’s thin capitalization rules taxpayers may need to review their thin capitalization position. Now every entity must have to consider whether their liabilities are debt or non-debt and the effect on the
See MorePortugal: Extraordinary investment tax credit to boost investment is introduced
The Portuguese government introduced an extraordinary investment tax credit with effect from 17 July 2013. The special tax credit will be applicable to investments between 1 July 2013 and 31 December 2013, up to a limit of EUR 5,000,000. The tax
See MoreUK: Corporation tax statistics
On 30 August 2013 HMRC released the latest corporation tax statistics. The publication shows the statistics for corporation tax receipts for 2012/13 and some revised figures in relation to corporation tax liabilities of previous years. Also shown
See MoreChina: Eligibility of software enterprises for corporate income tax incentives
To clarify the rules concerning software enterprises that are eligible for certain corporate income tax incentives, China’s State Administration of Taxation has issued guidance on the issues arising in qualifying for these incentives. According
See MoreCroatia: Government proposes amendments to Individual Income Tax Law
The government has proposed amendments to the Individual Income Tax Law on 25 July 2013. Following the constitutional court decision these amendments provide that dividends or participation in profits obtained after 31 December 2000, but paid out
See MoreDenmark :Corporate income tax rate will be reduce to 22% by 2016
The Danish Parliament has recently passed two bills which are part of the government’s economic growth plan. The current corporate tax rate is 25% but this will be reduced to 22% by 2016 under the growth plan. The phased-in reduction of the
See MoreTanzania – Requirements for business licenses
Recently Tanzania’s Ministry of Industry and Trade issued details of the procedures necessary for businesses to register for or renew their business licenses on or before 31st December 2013. In July 2013 the Permanent Secretary in the Ministry of
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