Netherlands – Withholding tax on dividends distributed to foreign shareholders
It was reported on 31 December 2013 that the Dutch Supreme Court filed with the Court of Justice of the European Union requests for preliminary rulings in three cases concerning the imposition of Dutch withholding tax on dividends distributed to
See MoreIndia – Arm’s length price for sourcing support services
The Delhi High Court has held that the Transfer Pricing Officer’s determination of an arm’s length price based on a 5% markup of the “free on board” (FOB) value of goods sourced for a related party’s contract with third parties was
See MoreRussia: Taxable base for corporate property tax
The Russian Ministry of Finance published on 11 December 2013 details of the application of the corporate property tax for immovable property located in Russia and held by a non-resident company, which does not have a permanent establishment in
See MoreMexico: Tax Reforms bill published
According to a media report Mexico reform tax bill on 23 December 2013, which might affect the direct and indirect taxation of corporate taxpayers, has been published in the country’s Official Gazette, completing the approval procedures. The
See MoreUS States Cut Taxes in 2013
Eighteen US states have cut taxes in the 2013 legislative year, reflecting an emphasis, following the recession, on pro-growth reforms that encourage economic expansion and competition, according to a new report by the Center for State Fiscal Reform
See MoreTax treaty between India and United Kingdom – Indian decision on taxability of fees for technical services
The Indian Income Tax Appellate Tribunal (ITAT) issued its decision on 31 May 2013 in the case of Veeda Clinical Research Private Limited (ITA 1406/Ahd/2009) that the provision of market awareness and development in-house training services to an
See MoreIndia: Determines guarantee rates on loans are arm’s length
The Mumbai Bench of the Income-tax Appellate Tribunal held that bank guarantee rates cannot be mechanically applied in determining the arm’s length price. The tribunal explained the difference between corporate guarantee and bank guarantee, and
See MoreCanada: Legislation sanctioning Manitoba’s 2013 budget
By enacting legislation Manitoba’s 2013 budget evaluates took Royal Assent on December 5, 2013. The budget belonging tax measures provisions that: Corporate capital tax rate on financial institutions has to be increased from 4% to 5%; The
See MoreTurkey – CIT relief from certain services
A circular provides for the possibility of exempting 50% of the profit provided to non-residents for corporate income tax purposes and earned by Turkish taxpayers from certain types of services. Now, companies who may benefit from the 50% relief
See MoreTax credits for creating job in South Korea
The government of South Korea is planning to give more tax incentives to corporate and personal financing in culture and leisure activities like libraries, museums, art galleries and performance in theaters. An additional tax credit of 3 % will be
See MoreSpanish Bioindustry Welcomes R&D Tax Breaks
During a recent event organized by the Spanish Bioindustry Association Asebio, Spain's State Secretary for Finance presented details of the tax incentives introduced within the framework of the Entrepreneur Support Act, which is designed to promote
See MoreRussia–Readjusting the taxable base for transfer pricing purposes may impact on the VAT base
The Russian Ministry of Finance has made public Letter No. 03-01-18/19214 clarifying the rights of tax authorities to readjust the taxable base in the case of selling goods and performing of works or services between related parties. Article 105.3
See MoreRussia-Applicable fields for applying thin capitalization rules
The Ministry of Finance has published Letter No. 03-08-05/23521 regarding the applicability of the thin capitalization rules to interest payments made by a Russian company on a loan granted by a Russian bank issued on June 21, 2013. For example, a
See MoreIndia: Determines arm’s length price of share transfers
The Income-tax Appellate Tribunal has held that the discounted cash flow method was preferable over the “yield” method or “net asset value” method for purposes of determining the arm’s length price of shares transferred to related parties.
See MoreSwitzerland: Tax burden remain stable in 2014
According to a media report, the Swiss Federal Department of Finance has issued its tax exploitation index for 2014 on 10 December 2013; it disclosed that the average tax burden in Switzerland will remain same in 2014, compared to 2013. On average,
See MoreCanada -Partnership information return for 2013
The Canadian Revenue Agency (CRA) has issued revised guidance for partnership information returns (Guide T4068), Guide for the Partnership Information Return (T5013 Forms) for the year 2013. The Guide T4068 contains changes to the forms, schedules
See MoreCanada – Making Declaration of proposed tax changes in Ontario
The Finance Ministry in Ontario has declared proposed measures to increase the tax rate on “non-eligible dividends” of up to 3.9% which was effective from January 1, 2014. Other proposed measures would include: Certain research and development
See MoreBelgium confirms withholding tax rate changes
Belgium has decided to reduce the rate of withholding tax levied on small- and medium-sized enterprise (SME) dividends from 25 percent to 15 percent; and it is a confirmation from The Belgian Prime Minister. In order to encourage entrepreneurs to
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