India – 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
See MoreCzech Republic: Income Tax Law amendment has approved
The Senate of Czech Republic has approved a special law measure on October 10, 2013 which includes a long discussed Income Tax Law amendment. To be enacted it must be accepted by a new Chamber of Deputies on its first session. Under the new
See MoreAustralia: Documentation of R&D activities
As like other nations, Australia gives tax relief to companies taking part in research and development activities. However companies need to hold satisfactory documentation to show that their activities fall inside the meaning of these activities
See MoreArgentina -Tax Incentives Plan for software Industry
The Argentine government issued a decree on 16 September 2013 to promote the software industry. The decree will allow tax incentives to individuals and legal entities whose core activities are in the software sector and is anticipated to promote the
See MoreJapan: Published Fiscal Incentive Package
Japanese Prime Minister has confirmed on 4 October 2013 that, the Government is to provide a fiscal stimulus package to counteract the declining effects of a 3 percent consumption tax rate rise due next year. He also disclosed on 1st October
See MoreIndonesia-temporary tax payment relief
A new regulation providing a temporary cash flow relief for some taxpayers has been issued by The Ministry of Finance of Indonesia. The regulation is intended to sustain the positive cash flow of certain taxpayers for creating stable macro economy,
See MoreIndia: CBDT issues rules for application of GAAR
The government of India has allotted a General Anti Avoidance Rule (GAAR) in order to combat tax avoidance. The GAAR which was originally introduced in the 2012/13 budget will be effective from 1 April 2016. The Rules are applicable for tax years
See MoreGreece: Current transfer pricing legislation changes
Recently, major transfer pricing regulation changes have taken place in Greece. A bill was approved on 29 August 2013 by the Greek Parliament to expand the deadline for disclosing to the tax authority the inter-company transactions within a group
See MoreFrance: New 1% tax on EBITDA repealed
The French Minister of Economy officially announced on 6 October 2013 that the new 1% tax on Earnings before Interest, Tax, Depreciation and Amortization (EBITDA) will be repealed and a new temporary surtax on the corporate income tax will be
See MoreChina: Scope for 50% tax deduction on R&D expenses
The Ministry of Finance of China on 30 September 2013, released a circular which expands the criteria for enterprises to be eligible to claim the extra 50 percent tax deduction on expenses incurred from research and development. The super tax
See MoreBrazil: Procedure to file requests for tax consultations
Brazil issued Normative Instruction 1,396/2013 on 30 September 2013.This Instruction regulates the administrative procedure to consult the federal tax authority on the interpretation of the tax and customs legislation concerning taxes administered
See MoreBrazil: Tax authority has issued ruling on tax treatment
The Federal Tax Authority issued Ruling No. 58/2013 on 27 August 2013, published in the Official Gazette on 30 August 2013, concerning the tax treatment of amounts deposited into escrow accounts associated with specific conditioned
See MoreBrazil: Changes to transfer pricing regulations
Brazil issued Normative Instruction 1,395/2013 on 30 September 2013.This Instruction introduced changes to Normative Instruction 1,312/2012 regarding the prices that must be used in cross-border transactions involving the sale and purchase of goods,
See MoreUruguay – Taxation procedure of public companies transferred to foreign country
An advisory firm of Uruguay recently issued a report concerning the transfer of public companies to a foreign country (and vice-versa). Generally those companies are no longer subject to Uruguay’s corporate income tax (since the company is no
See MoreCanada – Evaluation of GST/HST information
The Canadian Revenue Agency has began to judge the “hefty penalties” regarding the GST/HST annual information return that many large businesses and financial institutions in Canada are needed to report. The penalties (which can be as high as
See MoreUK: Judicial decisions on capital allowances
The Upper Tribunal rejected an appeal from HMRC against a capital allowance claim in a recent decision involving Lloyds TSB Equipment Leasing. The claim related to finance leases in relation to two liquid natural gas (LNG) vessels that were leased
See MoreChanges in e-Filing Tax Payments in South Africa
E-filing on debt pull transactions will be eliminated from September 4. The SARS disclosed that the procedure will take place over one month after an alert message will appear on e-filing, where a debt pulls transactions is no longer available.
See MoreBelgium: Notional interest deduction rate
June 2013 Legislation modifies the method which is used to calculate and determine the rate of the notional interest deduction. On the basis of the average return of the 10-year government bond (OLO) in the months July, August and September it is
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