Peru: Amendments to income tax rates
In Peru, Law Decrees Nos. 1258 and 1261 establishing certain amendments to the Income Tax Law were published in the Official Gazette on 8 and 10 December 2016 respectively. According to the amendments the general corporate income tax rate has been
See MoreCanada: Income Tax Folio on capital dividends published
The Canada Revenue Agency (CRA) has published an Income Tax Folio on 15th December 2016 regarding capital dividends (S3-F2-C1). The new Folio is open for comment up to 16th March 2017. Additionally, a general overview of capital dividends and the
See MoreKorea-Tax Bills for 2017 passed by the National Assembly
The Korean National Assembly passed the Tax Bills for 2017 on 2 December 2016 which was announced by the Ministry of Strategy and Finance (MOSF) on 28 July of 2016. According to the adopted Bill the amount of loss carried forward that a foreign
See MoreCanada: CRA updates a publication about non-Resident tax withholding and remitting
The Canada Revenue Agency (CRA) has updated its publication, T4061 NR4 entitled ‘Non-Resident Tax Withholding, Remitting, and Reporting 2016’ on 6th December 2016. The new publication explains that residents of Estonia have been exempt from tax
See MoreUS: IRS issued on guidance on payment of dividend equivalents from US sources
The Internal Revenue Service on 2 December 2016 issued Notice 2016-76 to provide guidance on compliance in 2017 and 2018 with the final and temporary regulations issued under sections 871(m), 1441, 1461 and 1473 of the US Internal Revenue Code
See MoreTaiwan: Debentures and corporate bonds exemption extends
The Legislative permitted the modification of securities transaction taxation, extending the exemption for further 10 years, which means that the securities transaction tax on bank debentures and corporate bonds will be suspended until 31 December
See MoreFrance-ruling on 75% withholding tax on dividends paid to residents of NCSTs in accordance with constitution
The Constitutional Court of France delivered its decision (No. 2016-598 QPC, Eurofrance) on 25 November 2016 about the compatibility with the constitution of the 75% withholding tax rate applicable to dividends paid to a resident of a
See MoreFinland: Income received from China on mobile games treated as royalties
The Finnish supreme administrative court issued an order that income on mobile games received by the Finnish company from the Chinese company, under the agreement, constituted royalties in accordance with the treaty. The issue in this case was
See MoreItaly: Resolution publishes regarding interest on medium or long-term loans
The Italian Tax Authorities issued Resolution No. 84/E on 29 September 2016, providing clarifications on the tax treatment of qualifying interest on medium or long-term loans, following the amendments introduced by Law Decree No. 91 of 24 June
See MoreUkraine: Ministry of Finance clarified advance payments of corporate income tax on dividends
The Ministry of Finance (MoF) issued Guidance Letter No. 31-11130-09-10/21370 dated on July 25, 2016, explaining the corporate income tax treatment of dividends paid by Ukrainian residents. According to letter, dividends received by the companies
See MoreUruguay-Tax measures of the Accountability Bill
The chamber of Deputies of Uruguay received for discussion the Accountability Bill on 20 June 2016. The Bill was issued by the Executive Branch. The Bill consists of several tax measures. The corporate income tax measures included in the Bill are as
See MoreRussia: MoF clarifications regarding interim dividends
The Finance Ministry (MoF) has issued a letter No. 03-03-06/2/21011 on 13th April 2016 describing the tax treatment of interim dividends paid by a Russian company to its company shareholders in an amount exceeding the net profits of the company in
See MoreAlgeria: Issued Tax Free Government Bonds
The Algerian Tax Administration issued a Note pertaining to the issuance of government bonds starting from 17 April 2016. Interest income from those bonds will benefit from a tax exemption. Subscriptions will be available for both individuals and
See MorePoland: Proposes amendments for corporate and personal income tax law
Minister of Finance presented the proposal of amendments to laws on income taxes for both corporate and personal on 25 February 2016. According to the amendments the exemption from withholding tax on interest, royalties and fees for intangible
See MoreRussia: FTS clarifies tax treatment of dividends received by a foreign company
The Federal Tax Service (FTS) has issued a letter no. SD-4-3/2765 on 19th February 2016 for clarifying the tax treatment of dividends received by a foreign company which voluntarily chooses to be considered as a Russian tax resident. According to
See MoreNetherlands: IMF paper comments on the tax system
On 11 February 2016 the IMF issued a staff report and selected issues paper in connection with discussions with the Netherlands under Article IV of the IMF’s articles of agreement. The selected issues paper covers the possibility of further tax
See MoreNorway: Fiscal Budget for 2016 Approved with Tax Measures
The Norwegian Government has approved its 2016 Fiscal Budget on 14 December 2015. The corporate income tax rate has been reduced from 27% to 25%. The current limit of NOK15 million increases to NOK20 million for in-house research and development
See MoreFrance: Abolition of add-back on dividends within tax-consolidated groups
An amendment was adopted by the National Assembly on 2 December 2015 to abolish the neutralization within tax consolidated groups of the 5% add-back on dividends qualifying for the participation exemption. The add-back will therefore be reduced to
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