Austria: Withholding tax on dividend increases
In July 2015 the Austrian Parliament approved the Tax Reform Act 2015/2016 and this includes a provision to increase the rate of withholding tax applicable for dividend distributions made to non-resident companies. The law provides that with
See MoreECJ: Advocate General issues an opinion involving dividend taxation and free movement of capital
The Advocate General of the European Court of Justice (ECJ) issued an opinion on 10 September 2015 in the case of Pensioenfonds Metaal en Techniek v Skatteverket (Case C-252/14). The Supreme Administrative Court of Sweden had asked the ECJ for a
See MoreRomania: New fiscal code published addressing corporate tax regime amendments
Romanian government published the Law no. 227/2015 regarding the Fiscal Code on 10 September, 2015. The new Fiscal Code, coming into force in 2016 which brings the following amendments for the corporate and micro-enterprise income taxation
See MoreGermany: Ratification of Protocol to OECD Convention on Mutual Administrative Assistance in Tax Matters
Germany deposited its instrument of ratification on 28 August 2015 for the protocol to the OECD Multilateral Convention on Mutual Administrative Assistance in Tax Matters. It is anticipated that the agreement will enter into force on 1 December
See MoreECJ: decision in Groupe Steria case on freedom of establishment
On 3 September 2015 the European Court of Justice (ECJ) issued a decision in the Groupe Steria case which concerned the application of the principle of freedom of establishment under EU law. In the relevant years the parent company of the group was
See MoreUK: taxation of dividend income of individuals
On 17 August 2015 the UK tax authority HMRC issued a fact sheet explaining the new rules for taxation of dividends received by individuals. With effect from April 2016 the current dividend tax credit is to be scrapped and a dividend allowance of
See MoreCyprus and Iran sign Income Tax Treaty
The Republic of Cyprus and the Government of Iran signed an Income Tax Treaty on August 4, 2015 for the Avoidance of Double Taxation. The treaty will come into force after the two countries exchange ratification instruments. Under the treaty, the
See MoreMauritius: Signing of MOU with South Africa
South Africa and Mauritius have signed a memorandum of understanding (MOU) on 22 May 2015. Following the signature of the MOU the revised Double Taxation Agreement between the two countries is expected to become effective from 1 January 2016. To
See MoreRussia: Application for participation exemption by a tax agent
The Finance Ministry (MoF) has issued Letter No. 03-03-06/1/885 on 19th January 2015 for describing the application of the participation exemption by a tax agent giving dividends to a Russian company. In accordance with article 284 (3) of the Tax
See MoreEgypt: Rules for Dividend taxation, electronic tax payments
In Egypt, there are rules for the taxation of dividends and requirements for electronic tax payments by joint-stock companies and state-owned entities. Dividend tax for corporate entities: For corporate entities, the dividend tax applies at a rate
See MoreChile: Tax administration clarifies income tax treatment from bonds and other debts instruments
The tax administration has issued Ruling 604 of 25th February 2015 that describes income tax treatment derived by non-residents from bonds and other debt instruments. Article 1 of Law 20, 780 to article 11 of income tax law has introduced amendments
See MoreFinland: Proposal to amend the taxation of non-residents by assessment
Finnish Government proposes an amendment of the taxation for non-resident individual by assessment presenting a law proposal (HE365/2014) on 12 February 2015. The proposal entails that the taxation of non-resident individuals by assessment would be
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 MoreAzerbaijan: Tax Withholding On Income from Bank Deposits Needs To Take Into Account the Relevant Rebate
Senior officials of Ministry of Taxes and banks in Azerbaijan held a meeting on January 9. It was decided in the meeting that the tax withholding on incomes from bank deposits will be applied on the interests charged by 1 January 2015 taking into
See MoreIndia: Update on GST and management service fees
The Union Cabinet approved the Constitutional Amendment Bill on Goods and Services Tax (GST) on 17 December 2014 and this can be passed to parliament for consideration. The clearance of the Bill by the Cabinet was achieved by a compromise. It was
See MoreFrance: Assembly Passes Second Draft Finance Bill For 2014
The draft amending budget for 2014 was passed at first reading by the French assembly on 9 December 2014. The legislation also has been passed by the Senate, and enactment is now expected before the end of 2014. This second draft Finance Amendment
See MoreNigeria: Tax withheld on dividends from gas operations
A decision of a case entitled “Nigeria Agrip Co. Ltd v. Federal Inland Revenue Service (10th December 2014)” has been issued by the Tax Appeal Tribunal and it states that dividends paid by a gas exploration and production company and paid out of
See MoreNigeria: Interests on inter-company loans are tax-deductible
The Tax Appeal Tribunal held that Nigerian company prepared interest payments on its inter-company loans are tax deductible, given that the loans were got at arm’s length. In Nigeria, the taxpayer of Nigerian company was occupied in petroleum
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