Germany – Discovering recipients of deductible payments
The federal tax court of Germany (Bundesfinanzhof – BFH) has held that the tax authorities may require taxpayers to identify the recipients of payments that are deducted as businesses expenses. Otherwise, the tax deduction can be
See MoreCanada – Tax credits temporarily refundable in Quebec
The Quebec government declared three new temporary repayable tax credits. Individuals who investing in “eco-friendly” renovation work these temporary tax credits are for them. Certain corporations that acquire, or add to, buildings applied in
See MoreECJ: Advocate General opines on consortium relief issue
The advocate general has issued an opinion on a consortium relief issue referred to the European Court of Justice (ECJ) by the First Tier Tribunal (Tax Chamber) in the UK. The issue concerned a residence requirement imposed on the link company as
See MoreThe United Kingdom and South Africa set to work together to tackle offshore tax avoidance
The Ministry of Finance of South Africa issued a media statement on 12 October 2013, stating that United Kingdom and South Africa have agreed to work together to tackle offshore tax avoidance including through pressing for better international
See MoreJapan: Changes to consumption tax and corporate income tax
The Japanese government officially announced on 1st October 2013 its plan to modify “consumption tax” and “corporate income tax”. The highlights of the plan are summarized below: Consumption tax: In the period between 1 April 2014 and 30
See MoreIndia – 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,
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