United 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
See MoreUK Considering Tax For Foreign Property-Buyers
The UK Chancellor of the Exchequer refused to confirm reports that the Government is considering moves to impose Capital Gain tax on foreign investors for property sales in Britain, as a measure to control property prices in London. At present,
See MoreUK Energy Firms Allegedly Using a Loophole To Cut Tax Bills
Several UK energy companies were accused on 30 October 2013 for abusing a legal loophole with a view to cut their tax bills. It was revealed by The Independent newspaper and Corporate Watch research that more than 30 UK businesses have been
See MoreIsrael: Action required for releasing trapped profits by 11 November 2013
Only those companies have to apply the temporary partial relief from Israeli corporate income tax until 11 November 2013, who wish to release their trapped exempt profits that were accrued until December 31, 2011. Companies will have to submit their
See MoreGermany – Discovering recipients of deductible payments
The federal tax court of Germany (Bundesfinanzhof – BFH) has held that the tax authorities may require taxpayers to identify the recipients of payments that are deducted as businesses expenses. Otherwise, the tax deduction can be
See MoreCanada – Tax credits temporarily refundable in Quebec
The Quebec government declared three new temporary repayable tax credits. Individuals who investing in “eco-friendly” renovation work these temporary tax credits are for them. Certain corporations that acquire, or add to, buildings applied in
See MoreECJ: Advocate General opines on consortium relief issue
The advocate general has issued an opinion on a consortium relief issue referred to the European Court of Justice (ECJ) by the First Tier Tribunal (Tax Chamber) in the UK. The issue concerned a residence requirement imposed on the link company as
See MoreThe United Kingdom and South Africa set to work together to tackle offshore tax avoidance
The Ministry of Finance of South Africa issued a media statement on 12 October 2013, stating that United Kingdom and South Africa have agreed to work together to tackle offshore tax avoidance including through pressing for better international
See MoreJapan: Changes to consumption tax and corporate income tax
The Japanese government officially announced on 1st October 2013 its plan to modify “consumption tax” and “corporate income tax”. The highlights of the plan are summarized below: Consumption tax: In the period between 1 April 2014 and 30
See MoreIndia – Implications of GAAR from 2015
Recently, in India general anti-avoidance rule (GAAR) has been introduced which will become effective from 1 April 2015 (Financial Year 2015-16). The rules for application of the GAAR provide certain exceptions which clarify that the GAAR will not
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