Taiwan: Proposed Amendments to Transfer Pricing Rules
The Ministry of Finance of Taiwan has proposed changes to the transfer pricing rules (Tai Cai Shui No. 10304651710). The draft of amendments was released on 7 January 2015 for public comment. The modifications, which concern one new provision and
See MoreLuxembourg: Formalization of New Transfer Pricing Legislation and Documentation Requirements
The Parliament of Luxembourg has approved the draft law and has formalized the framework for Luxembourg transfer pricing legislation and introduced the transfer pricing documentation requirements. The new measures are effective from 1 January
See MoreTurkey: Draft order to change electronic tax filing
The tax administration has issued Draft Order No. 397 on 16th December 2014 regarding a public consultation on electronic tax filing. Taxpayers who want to register to communicate electronically with the tax authorities must have a suitable
See MoreDenmark: Filing a paper form is no longer possible for companies
The Ministry of Taxation announced, on 3 February 2015, a new schedule relating to the digitalization of corporate tax filing. A new schedule was required as the necessary adjustments to the IT systems will be more time-consuming and complicated
See MoreSouth Africa: Transfer Pricing Adjustments Regarding Withholding Tax Obligations
Under the income tax act, section 31(3), South Africa provide that any adjusted amount for transfer pricing and thin capitalization purposes, prior to 1 January 2015, constituted a deemed loan. The adjusted amount plus interest deemed to have
See MoreThailand: IMF reports on preliminary findings
The IMF has completed a mission to Thailand from 15 to 29 January 2015 to hold discussions in connection with the Article IV Consultation. The IMF is expecting Thailand to continue a gradual economic recovery in 2015 and growth is estimated at 3.5%.
See MoreEuropean Union: Anti abuse clause added to parent subsidiary directive
On 27 January 2015 the Council of the European Union (EU) amended the parent subsidiary directive to add a binding anti-abuse clause. This is designed to prevent tax avoidance and aggressive tax planning, and to ensure more consistency in the
See MoreUK: HMRC Receives Biggest Digital Self Assessment Ever
HM Revenue and Customs (HMRC) oversaw the biggest digital Self Assessment event ever this year, receiving 10.24 million tax returns by midnight on 31 January, it revealed today. A record 85.5% of these were sent online, with the busiest days for
See MoreRussia: Draft law on the thin capitalization rule submitted to State Duma
The Draft Law No. 675906-6 regarding the introduction of changes to article 269 of part 2 of the Tax Code in respect to the meaning of the concept of controlled indebtedness has been submitted to the State Duma on 16th December 2014. A
See MoreNigeria: Public notice of new filing rules for non-resident companies
The Federal Inland Revenue Service (FIRS) has issued a public notice in accordance with section 55 of the Companies Income Tax Act (CITA) on 28th January 2015 requiring all resident and non-resident companies to file their tax returns on a real
See MoreEcuador: introduces anti-abuse provision on loans to shareholders
Under new legislation loans made by Ecuadorian companies to non-resident shareholders are treated as dividends and therefore subject to Ecuadorian withholding tax. The applicable domestic withholding tax rate on dividends is limited to the
See MoreEcuador: Changes to corporate income tax
Generally Ecuadorian companies are subject to a 22% rate of corporate income tax. In accordance with the new law, if more than 50% of the company is owned by non-resident shareholders that are resident in “tax haven” jurisdictions, the
See MoreEcuador: Changes to capital gains tax
The tax reform in Ecuador includes measures regarding the taxation of capital gains related to indirect and direct transfers of shares of Ecuadorian corporations with increased rates of corporate tax imposed on shareholders of Ecuadorian
See MoreLatvia: Budget committee approves 9% Microenterprise tax rate
The Parliament Budget and Finance (Taxation) Committee approved in principle a draft bill which sets the micro-enterprise tax rate at 9% in the first three years since the company's registration. As reported, in 2015, the tax rate for
See MoreSpain: Modifies the transfer pricing legislation
In the “Corporate Income Tax Reform 2015” enacted under the Law 27/2014 the following transfer pricing rules are amended; Scope of related-party transactions - The ownership requirement for related parties is increased from 5% (1% in the
See MoreHong Kong: IRD Releases Revised Forms To Apply For Resident Status For Tax Treaties
The Inland Revenue Board of Hong Kong on January 29 released revised forms for companies, partnership, trusts, and other entities to apply for a certificate of resident status for purposes of claiming tax treaty benefits. With effect from 1 February
See MoreFinland: Tax Administration Publishes Guidance On Advance Tax Withheld On Dividend
Finish Tax Administration published guidance, on 26 January 2015, on advance tax withheld on dividends paid to resident natural persons and estates of deceased persons. The guidance named “Guidance No. A14/200/2015 of 22 January 2015” specifies
See MoreOECD holds public consultation on preventing the artificial avoidance of PE status
On 21 January 2015 the OECD held a public consultation on the artificial avoidance of permanent establishment (PE) status. This is action 7 of the action plan on base erosion and profit shifting (BEPS). The OECD Model tax treaty permits the host
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