Netherlands: 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
See MoreSlovakia: Corporate tax rate reduction, international tax rules changed
The Finance and Budget Committee of the National Council of the Slovak Republic recently proposed some changes to the Slovak Income Tax Act. The proposed changes cover reduction in the corporate income tax rate, carry forward of tax losses, transfer
See MoreUruguay: capital gains tax exemption on transfer of bearer shares repealed
The capital gains tax exemption on the transfer of bearer shares issued by Uruguayan companies has been removed by Art. 364 of Law No. 19,149, dated 24 October 2013.
See MoreBulgaria: Tax Increase for the Wealthy
The Bulgarian Government has confirmed that it intends to introduce a higher rate of tax for the wealthy during 2015. A new 15% rate would apply to those earning more than BGN2,700 (USD1,900) per month instead of the flat 10%. Other measures
See MoreUkraine: Rates and Accounting rules for Tax 2014
On 19 December 2013, the Verkhovna Rada of Ukraine passed Law No. 3757 that introduce tax rates and tax accounting rules for 2014. The corporate income tax rate is reduced to 18% (from 19%) with further decreases to 17% (beginning 1 January 2015)
See MoreClarification of Russian MoF on tax withheld not in accordance with the tax treaty
Russian Ministry of Finance has published a letter no. 03-03-06/4/44331 which was issued on 23 October, 2013. This explains if corporate withheld tax by a Bulgarian branch belongs to a Russian company may be benefited against the corporate tax
See MoreNorway Budget for 2014 – amendments
On 8 November 2013 the new Government presented its amendments to the Budget Bill for 2014. In general, the new Government is reducing taxes, whereas the former Government increased them. The amended Budget for 2014 contained the following
See MoreNetherlands – Withholding tax on dividends distributed to foreign shareholders
It was reported on 31 December 2013 that the Dutch Supreme Court filed with the Court of Justice of the European Union requests for preliminary rulings in three cases concerning the imposition of Dutch withholding tax on dividends distributed to
See MoreIndia – Arm’s length price for sourcing support services
The Delhi High Court has held that the Transfer Pricing Officer’s determination of an arm’s length price based on a 5% markup of the “free on board” (FOB) value of goods sourced for a related party’s contract with third parties was
See MoreRussia: Taxable base for corporate property tax
The Russian Ministry of Finance published on 11 December 2013 details of the application of the corporate property tax for immovable property located in Russia and held by a non-resident company, which does not have a permanent establishment in
See More