Australia – Reduces safe harbor for thin capitalization
Australia recently reduced the safe harbor rule for thin capitalization limit from 75% to 60%, corporate groups may want to consider what steps to take with respect to their thin capitalization positions. With effect from 1 July 2014 the permitted
See MoreCzech Republic: Obligatory reporting on related-party transactions
The Czech Tax Administration has declared a new reporting obligation for all entities accountable for corporate income tax in the Czech Republic who has dealings with related parties. Czech taxpayers will have to file a separate disclosure form
See MoreLithuania: Approved notification form for investment projects
The head of the State Tax Inspectorate under the Ministry of Finance approved the form PLN210 and its appendices by way of Order VA-34 on 5 June 2014. From 1 January 2015, companies that are preparation to take advantage of the investment project
See MoreCanada: Interest rates of prescribed income tax unchanged for Q4 2014
The Canada Revenue Agency has declared that the interest rates of prescribed income tax for taxable benefits overpaid and underpaid taxes for the fourth quarter (Q4) of 2014 i.e. from October 1, 2014 to December 31, 2014 will stay
See MoreFrance-Amended Finance Bill for 2014
The national assembly of France adopted the Amended Finance Law and the Amended Finance Law on Social Security for 2014 on 23 July 2014.The Constitutional Court will now review the law and after signing by the president the law will enter into
See MoreNigeria: Changes Income tax law for companies
According to section 55 of the income tax law for companies, the Federal Inland Revenue of Nigeria has declared a policy change and stated that non-resident companies will be required to file their returns. Non-resident companies have filed their
See MorePeru-New resolution on reporting of stocks and shares
The Peruvian tax authority issued Resolution 200-2014-SUNAT/4B0000 which entered into effect on 28 June. The resolution amended the Resolution 169-2014-SUNAT/4B0000. According to the new resolution Form 1065 need not to be filed for the issuance,
See MorePhilippines: BIR strengthens control over large taxpayers
The Bureau of Internal Revenue (BIR) has strengthened its monitoring of the country’s large taxpayers, particularly on the value-added tax (VAT). BIR’s collections of first half of this year reached PHP643.2bn (USD14.8bn), which is more than
See MoreChile: The Senate endorses tax reform bill
According to a statement from the Ministry of Finance, the Chilean Senate has approved tax reform bill from the President on July 15, 2014. An agreement between the government and the Senate's Finance Committee has taken place earlier this month for
See MoreQatar: An unique incentive have been introduced by the QFC
An unique and innovative incentive have been introduced by the Qatar Financial Centre (QFC) Authority as amendments to the Tax Regulations and Tax Rules regarding using new areas of tax relief and tax losses, mostly providing an advantage for Qatar
See MoreRussia: Revised draft changes related to introduction of CFC rules
The Ministry of Finance has released a revised version of the draft law regarding introduction of CFC rules. The important changes of the revised draft law are given below: • Concepts regarding “Beneficial owner” and “actual right to receive
See MoreUS: Government tends to curb on Offshore Deals
The Obama administration called for immediate congressional action to stop U.S. companies from using cross-border mergers to avoid the country’s tax system. A growing number of U.S. companies are looking to escape their federal tax bills by
See MoreVietnam: Issues new Circular on Corporate Income Tax
The Ministry of Finance published Circular No. 78/2014/T-BTC (Circular No. 78) on 18 June 2014, which provides additional execution guidance in respect of Decree No. 218/2013/ND-CP (Decree No. 218) which was issued on 26 December 2013. Decree 218,
See MoreIndia: Introduces new rules aim to reduce transfer pricing tax disputes
The government of India introduced new tax rules with their new budget target to reducing litigation with multinational firms over cross-border transactions the government considers tax avoidance schemes. Now days, transfer pricing is an application
See MoreSlovak Republic: New improvements in Transfer Pricing
The Financial Directorate in Slovak Republic has issued a methodological guideline on the application of transfer pricing methods. According to the changes to the OECD Transfer Pricing Guidelines in July 2010, the amendment to the ITA has abolished
See MoreAustria: Government accepts bill amending the Fiscal Criminal Act
The Austrian parliament accepted the bill amending the Fiscal Criminal Act 2014 on July 2014. The draft bill aims at finish the exercise of partial disclosures as the current rules allow taxpayers to benefit from a repeated voluntary disclosure
See MoreSingapore: Invites the Public to Consults on Stamp Duty Changes Bill 2014
The Ministry of Finance will be conducting a public consultation on the draft Stamp Duties (Amendment) Bill 2014 from 7 July 2014 to 25 July 2014. The draft Stamp Duties (Amendment) Bill 2014 provides for three changes to the Stamp Duties Act. The
See MoreTanzania: regulations on transfer pricing released
The Transfer Pricing Regulations in Tanzania has finally been released through Government Notice No. 27 of 2014 and which is effective from 7 February 2014. The Income Tax Act 2004 already had a requirement in section 33 to transact between
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