UK: Terms of Reference issued for GAAR advisory panel
The legislation in respect of the General Anti Abuse Rule (GAAR) in the Finance Bill 2013 provides for the appointment of a GAAR advisory panel. The panel is to consider and approve HMRC’s guidance on the GAAR. It is also required to consider
See MoreIndia: Requirements For Transfer pricing’s “deemed international transaction”
India’s transfer pricing rules are designed to prevent the use of transfer prices between related enterprises to shift profits away from India to a lower tax jurisdiction. The rules are therefore generally concerned with international transactions
See MoreCanada – Tax-related interest rates for 2014
It was announced by the Canada Revenue Agency (CRA) that tax-related interest rates for taxable credits and for tax overpayment and underpayments for the third quarter of 2013 (July 1- September 30) will remain unchanged for this year and the rates
See MoreUK: HMRC analyses data on tax schemes
The UK tax authority HMRC has received information indicating the extensive use of tax schemes to hide assets in overseas locations and it is working with the governments of Australia and the US to analyze a large amount of data. The data indicates
See MoreNorway : Tax Cut Plan for 2014
The Norwegian Prime Minister announced plans on 5 May 2013 for a modest tax cut for mainland businesses and for increasing taxes on oil companies and multinationals. This plan includes a reduction in the general corporate tax to 27% from 28%
See MoreAustralia: Proposal to amend GAAR
The Australian government on 13th February 2013 introduced Tax Laws Amendment Bill 2013. According to Tax Laws Amendment Bill 2013, companies will have to ensure that the commercial and other factors motivating a decision are properly documented.
See MoreUkraine: Draft Law amendments regarding the formation of a tax group
Draft Law No. 2737 introduces amendments regarding the formation of a tax group. On 5 April 2013, amendments to the Tax Code were sent to be approved by the parliament. The legislation will allow companies in Ukraine to form a consolidated tax group
See MoreChina: Taxable presence of foreign entity’s seconded workers
Recently a guidance concerning when the cross-border secondment of expatriate workers by foreign enterprises into China may give rise to a taxable presence in China is issued by the China’s State Administration of Taxation. Factors taken into
See MoreAustria:Corporate tax guidelines limit interest deductions
The Austrian Ministry of Finance published revised corporate income tax guidelines in March 2013, to tightening the rules with respect to interest deductions in connection with “debt push-down models” and concerning tax loss carry forwards
See MoreUK: HMRC issues revised GAAR guidance
HMRC’s latest guidance on the application of the General Anti-Abuse Rule (GAAR) was approved by the GAAR Advisory Panel on 15 April 2013. This guidance summarizes what the GAAR is intended to achieve and how it operates to arrive at this
See MoreGreece: Extension of Deadline for submission of certain tax returns
The deadline for submission of the tax returns for taxpayers falling into the scope of article 4 of paragraph 2 of the Income Tax Code has been extended until 31 May 2013, by the Ministry of Finance and all the tax returns are to be submitted solely
See MoreColombia: Introduces Corporate Tax Reforms
The Colombian Government has introduced measures relating to corporate tax changes. For the purposes of corporate tax, it redefined the concept of permanent establishment. Corporate income tax rate for companies and for non-resident companies
See MoreKorea: Update on rules for application of arm’s length standard to head office–branch transactions
Korea’s Ministry of Strategy and Finance has issued new regulations to clarify the method for calculating domestic-source income from intra-company transactions between a foreign head office and its Korean branch. This follows the passing of the
See MoreFinland Plans to Cut Corporate Tax Rate in 2014
On 21 March 2013, the government of Finland announced that it had reached an agreement on its tax plans for the tax years from 2014 to 2017. Finland plans to further cut its corporate tax rate to 20% from the current 24.5% rate, as of the beginning
See MoreSingapore: Budget for 2013
The Budget for 2013 was presented to Parliament by the Finance Minister on 25 February 2012. The Budget aims at increasing productivity and growth. Major changes include income tax rebates and restructuring of the Progressive Property Tax Regime
See MoreDanish Government plans to reduce corporate income tax rate
On 26 February 2013, the government published a document stating that it plans to reduce the corporate income tax rate to 22% (currently 25%). The reduction would be implemented gradually by reducing the tax rate by 1 percentage point between the
See MorePoland – Changes to transfer pricing documentation, thin capitalization rules
Legislation to expand the scope of Poland’s corporate income tax law is intended to be effective in 2014. The provisions of the legislation released on February 18, 2013 include changes to the transfer pricing documentation and thin capitalization
See MoreIndia: Budget for 2013
According to the Indian Budget 2013, the Government is considering for following major tax initiatives: the introduction of a Direct Tax Code (DTC), a goods and services tax (GST) and General Anti-Avoidance Rules (GAAR). The main changes are
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