Brazil: Tax Authority proposes Ordinance for corporate taxpayer classification
In accordance with the compliance efforts of Organization for Economic Co-operation and Development (OECD), tax authorities proposed an Ordinance regarding corporate taxpayer classification. The tax authorities need to analyze the capability of the
See MoreUS: Court of Appeals Withdraws Opinion in Altera case
On 8 August 2018 the US Court of Appeals (Ninth Circuit) announced that it was withdrawing its opinion of 24 July 2018 in the Altera Corp case, concerning the treatment of stock based compensation by related parties in a cost sharing arrangement
See MoreBulgaria: Council of Ministers approves draft Bill for amending income tax
The Council of Ministers approved a draft bill on October 10, 2018 and it have issued by the Finance Minister, Vladislav Goranov, on the Bulgarian Council of Ministers approved the draft bill issued by the Minister of Finance on 30 August 2018. The
See MorePhilippines: House of Representatives approves corporate tax reform bill
On 10 September 2018, the House of Representatives approved the Tax Reform for Attracting Better and Higher Quality Opportunities (Trabaho) bill 8083 (the Bill). Under the bill, the corporate tax rate will be gradually reduced by 2% every 2 years
See MoreIreland announces Budget for 2019
On 9 October 2018, the Budget for 2019 was presented to Parliament by the Minister of Finance. The summary of 2019 Budget measures are following: Corporate Tax Film Relief The scheme provides relief in the form of a corporation tax credit related to
See MoreNorway: Finance Minister presents National Budget 2019
The Minister of Finance, Siv Jensen, presented the draft National Budget 2019 on October 8, 2018 to the Parliament. The presentation of the budget will be followed by a cycle of parliamentary hearings and debates on the budget, which will last until
See MoreDenmark submits a bill to the parliament to transpose the EU Anti-Tax Avoidance Directives into Danish tax law
On 3 October 2018, the Danish Minister of Taxation submitted a bill to the parliament to transpose the EU Anti-Tax Avoidance Directives (ATAD 1 and ATAD 2) into Danish tax law. The proposals include the extension of the existing hybrid mismatch
See MorePeru introduces GAAR, new thin capitalization rule, definition of PE, and Other Changes
On 13 September 2018, the Peruvian government has published Legislative Decree No. 1422 and Legislative Decree No. 1424, which include measures for the implementation of the General Anti-Avoidance Rule (GAAR), new thin capitalization and interest
See MoreSweden:The Administrative Court approves the position of the tax administration on interest on withholding tax refunds
Recently, the Swedish Tax Agency issued a notice concerning a ruling by the Supreme Administrative Court stating that recipients of dividends on which taxes have been levied are entitled to interest if the tax is later refunded. The notice notes
See MoreUK: Statistics on Uptake of Patent Box Relief
From 1 April 2013 the UK phased in Patent Box legislation that allows companies to apply a lower rate of corporation tax to profits earned from patented inventions and other similar forms of intellectual property (IP). The relief was initially
See MoreNetherlands: Budget Proposals 2019
On 18 September 2018, the government of Netherlands presented the 2019 budget proposals to the House of Representatives. Implementation of ATAD measures The Proposals put forward legislation that introduces various EU Anti-Tax Avoidance Directive
See MorePeru: Added new thin Capitalization Rules and Amended Income Tax Law
Peru’s President enacted Legislative Decree 1424 on 13 September 2018, which amends the income tax law with regard to the thin capitalization rules, the indirect transfer of shares, the definition of permanent establishment (PE) and the indirect
See MoreBulgaria: Consultation on draft Law for implementing EU ATAD
The Finance Ministry is consulting on draft legislation for the execution of certain measures of the EU Anti-Tax Avoidance Directive (ATAD). A new interest limitation rule was proposed in this draft Law. This new rule would restrict the amount of
See MoreTurkey: Finance and Treasury Ministry increases interest rates for late payment tax
The Ministry of Finance and Treasury published a Decree No. 62 on September 5, 2018, in the Official Gazette. This Decree contains increase in monthly interest penalty for late payment taxes from 1.4% to 2.0%. Again then on September 6, 2018, a
See MoreSweden: Government announces a legislative proposal to amend the CFC rules
On 4 September 2018, The Swedish government published a legislative proposal to amend the country's controlled foreign company (CFC) rules to comply with the EU Anti-Tax Avoidance Directive (ATAD1). Under the CFC rules, income of foreign entities
See MoreGreece: Prime Minister announces some amendments in tax legislation
The Prime Minister, Alexis Tsipras, announced on September 8, 2018, plans for tax cuts and pledged spending to heal years of painful strictness, less than a month after Greece emerged from a bailout program financed by its European Union partners
See MoreIreland announces corporation tax roadmap
On 5 September 2018, the Minister for Finance and Public Expenditure & Reform, Paschal Donohoe T.D., has published Ireland’s Corporation Tax Roadmap. The Roadmap takes stock of the changing international tax environment, outlines the actions
See MoreUS: Appeal Court Overturns Altera decision on stock based compensation in CSAs
On 24 July 2018 the US Court of Appeals overturned the decision of the Tax Court in the case of Altera Corp, a case that concerned the inclusion of stock based compensation costs in cost sharing agreements (CSAs). The Appeal Court has determined
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