US: Legislation on Permanent Research and Development Tax Credit
The US House of Representatives has passed legislation that would simplify and strengthen the research and development tax credit and has included the provision in the US tax code. Companies conducting their development programs will be able to
See MoreTurkey: Unilateral APA updated
The tax administration has announced that it has concluded preparations for conclusion of a unilateral Advance Pricing Agreement (APA) between the tax administration and a taxpayer. According to the 5th paragraph of article 13 of the transfer
See MoreNigeria: System allowing electronic tax payment
The Federal Inland Revenue Service has announced an e-tax system that permits taxpayers to make electronic remittances. All taxes and levies payable to the tax administration in Nigeria can be paid by using this new
See MoreChile: Circular 30 regarding administrative interpretation published
A Circular 30 of the tax administration (Servicio de Impuestos Internos, SII) about SII's administrative interpretation concerning amendments introduced by Law 20,780 to the Income Tax Law and specifically, it contains the new article 41 G on CFC
See MoreUK: New share valuation rules for CGT
The UK tax authority HMRC has published new valuation rules in respect of the valuation of shares for capital gains tax (CGT), corporation tax and income tax purposes. The rules which apply from 6 April 2015 are in the Market Value of Shares,
See MoreOECD Proposes Threshold for MNEs to File Country-By-Country (CbC) Report
The OECD has confirmed that all multinational enterprises (MNEs) should be required to file the Country-by-Country (CbC) report every year. MNEs with annual consolidated revenues in the immediately preceding fiscal year of less than €750 million
See MoreWorld Tax Brief : March & April 2015
United Kingdom Main Corporate tax Rate: The main rate of Corporation Tax for 2015 is 20% (With the exception of oil and gas companies with ring fence profits) from 1 April 2015. The Corporation Tax will be charged at a single rate known as the
See MoreWorld Tax Brief : January & February 2015
Belgium Taxability of other income: From 2015 small and medium sized companies may create a "liquidation reserve" from after-tax profits. The liquidation reserve is immediately subject to a separate tax of 10%. Upon liquidation, no dividend
See MoreSpain: Government approves special tax regime for the Canary Islands
The Spanish Government has approved the agreement with the European Union (EU) Commission for the new Spanish special tax regime for the Canary Islands (Zona Especial Canaria, or ZEC ), which entered into force on January 1, 2015. The regime is
See MoreChile: Tax administration clarifies tax treatment of gains from exclusion of shares
Tax administration has issued Ruling 1016 of 14th April 2015 which explains the tax treatment of gains from the alienation of shares issued by joint-stock companies incorporated in Chile. Those gains are omitted from income tax, inter alia, under
See MoreUK: Main Rate of Corporation Tax Falls to 20% and is Unified
The main rate of Corporation Tax for 2015 is 20% (With the exception of oil and gas companies with ring fence profits) from 1 April 2015. The Corporation Tax will be charged at a single rate known as the main rate. The small profits rate was
See MoreTurkey: General Communique on corporate tax exemption released
The General Communique No. 8 regarding Corporate Income Tax has been published in the Official Gazette on 21st April 2015 and it changes General Communique No. 1 on Corporate Income Tax. This also gives information desired for the implementation of
See MorePoland: New thin capitalization rules
The thin capitalization rules changes in Poland and this rule enacted as an amendment to Poland’s corporate income tax law, and signed by the president on 17 September 2014 and from 1 January 2015 the “thin capitalization” rules has been
See MoreNamibia: Budget proposals for 2015-16
The Namibian budget speech for 2015-16 was delivered on 31 March 2015. In the budget it was proposed to reduce the corporate income tax rate for non-mining companies from 33% to 32%. There will be no change in the corporate tax rate for mining
See MoreFrance: Intergroup services marked out in tax-avoidance transactions list
The French tax administration has recently published an updated list of abusive practices and fixtures that are considered to be contrary to the law. Among these are certain inter-group arrangements. Relocation of profits after restructuring:
See MoreRussia: Law concerning notification process of CFCs adopted
The parliament has approved Law No. 667946-6 on 27th March 2015 for extending the deadline of tax resident’s notification about the involvements held in controlled foreign companies (CFCs). The deadline for notification has been extended from 1st
See MoreRussia: State Duma considers new draft law regarding thin capitalization rules
The Russian State Duma Council accepted the decision on 17th February 2015 to incorporate a new draft of Law No. 724609-6 on the introduction of changes to Article 269, Part 2 of the Tax Code regarding the meaning of controlled debt. The draft law
See MoreUK Issues Guidance on the Diverted Profits Tax
The UK included legislation to introduce the Diverted Profits Tax in the Finance Bill for 2015. Guidance on the tax was updated on 30 March 2015 to explain the changes to the provisions since the draft legislation was first published. The guidance
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