Russian Appeal Court rules on thin capitalization
Russia’s Arbitration Court of Appeal issued a decision on 24 February 2014 holding that a loan from a foreign related company of United Bakers Pskov LLC1 was subject to the thin capitalization legislation. This ruling by the Court was made on the
See MoreCyprus – Due date for 2012 corporate return extended
According to a recent announcement of the Inland Revenue Department in Cyprus the deadline for electronic filing of corporate tax returns for 2012 has been extended and is not fixed at 30 June
See MoreNew Zealand: New rules for determining tax residence
In New Zealand the Inland Revenue Department has issued an “interpretation statement” on tax residence. This is an update to previous guidance from 1989. The new statement takes effect from 1 April 2014 and includes residence criteria for
See MoreFrance- Court Rules in Research Tax Credit Case
In France a tax credit known as the Crédit Impôt Recherche (CIR) is available for certain research and development expenditure by businesses. A recent case (No. 1219816) involved an appeal from a business advisory firm, in respect of the partial
See MoreFrance Reintroduces Rules for Creative Tax Credit
The creative tax credit is given to innovative enterprises in the area of arts and crafts. A company in this sector may obtain a 10% tax credit for expenditure on new products, including the cost of wages, design and protection of new models. The
See MoreUS – New York suspends driving licenses of tax evaders
Last year New York passed legislation providing for the suspension of the driving license of any individual owing a sum greater than ten thousand dollars in back tax. This has apparently been a successful policy as thousands of individuals have
See MoreTaiwan increases business tax rate for financial services
Taiwan has amended the laws on income tax, VAT and business tax with an effective date of 1 January 2015 in the case of the income tax changes. The measures include an increase of the business tax rate on core business revenue in banking and
See MoreSwitzerland Adopts Anti-Tax Evasion Bill
The Swiss Council of States has approved a Bill in respect of the revised recommendations of the Financial Action Task Force (FATF). The Bill raises the qualifying threshold for serious tax offences and therefore helps the fight against tax evasion.
See MoreSweden to Investigate Tax Incentives for SMEs
Sweden is looking at the tax treatment of entrepreneurs, start ups and small businesses with a view to improving the competitiveness of the country’s business and increasing employment. An investigation has been launched to consider the changes
See MoreRussia Clarifies transfer pricing for Domestic Transactions
Letter No 03-01-18/2080 issued by the Russian Finance Ministry on 22 January 2014 clarifies that some domestic transactions are to be subject to the transfer pricing rules as they are deemed to be controlled transactions for this purpose. These
See MoreSpanish SMEs Ask for VAT and Income Tax Support
The President of Spain's small business association CEPYME, has called on the Government to lower the rate of corporation tax levied on small- and medium-sized enterprises (SMEs) in Spain, as part of its plans to reform taxation. He also recommended
See MoreItalian Supreme Court rules on tax residence concept
The Italian Supreme Court gave its decision on 17 January 2014 in case No. 1811 concerning the issue of whether the Maltese company should be considered resident in Italy for tax purposes. The case particularly concerned the provision that a company
See MoreIreland: opportunities for US firms
The Irish Prime Minister has described the 12.5 percent corporate tax rate as a "cornerstone of the offering of attractiveness that Ireland has," telling the US Chamber of Commerce that his country is open for business. Although a few years ago
See MoreEcuador: Income tax exemption on deposits and investments in securities
On 21 February 2014, the General Director of the Internal Revenue Service published Circular No. NAC-DGECCGC14-00003 in order to communicate the tax authority's application of the substance over form principle as a criterion for the application of
See MoreRomania: Information regarding late penalty payment provisions
After arising from 1st March 2014, the late tax payment penalty relating to liabilities is 0.03% per day of delay in addition to the payment of interest at the applicable
See MoreMexico: Annual tax return application available for individuals
The Mexican Tax Administration Service (SAT) has informed taxpayers who derived income from salaries in 2013 that they will receive their tax refund within the following 5 days after submitting the tax return. The deadline for submitting the annual
See MoreMalaysia- issues filing program for calendar year 2014
The Inland Revenue Board of Malaysia has issued the filing program for 2014: Non-corporate entities: Form Deadline period for submission Form E – Return Form of Employer 31 March 2014 hand
See MoreIreland – Evaluation of R&D tax credit regime
Ireland’s Department of Finance in 2013 undertook a comprehensive review of the Irish research and development (R&D) tax credit regime, to determine that the R&D tax credit provides “value for money” for taxpayers. The review had 5 key
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