Russia: Draft amendments to CFC rules
A draft of Federal Law No. 953192-6 regarding the СFC provisions was submitted to the lower chamber of the parliament on 14th December 2015. The CFC provisions were first provided by the Tax Code and Federal Law No. 376-FZ of 24 November 2014. The
See MoreRussia: MoF clarifies interest expense regarding loans
The Ministry of Finance (MoF) has recently released Letter No. 03-03-06/1/63388 to clarify the applicable tax treatment of interest expense incurred on a loan used to pay dividends. According to Article 252 of the Tax Code (TC) a taxpayer may
See MoreEgypt: Clarification guideline with respect to corporate taxation
The Egyptian Tax Authority published Guideline No. 28 for 2015 on 12 November 2015. The Guideline clarifies certain issues with respect to changes introduced by Decree Law No. 96 for 2015 which amended Income Tax Law No. 91 for 2005. The most
See MoreMexico published the Federal Revenue Law for 2016
Mexico published the Federal Revenue Law for 2016 (the Decree) in the Official Gazette on 18 November 2015 and the decree will be effective from 1 January 2016. The main requirements are given below: Tax Incentives: Tax incentives are available
See MoreDenmark publishes a draft bill to relax the taxation of outbound and inbound dividends
The Danish Minister of Taxation published a draft bill on 5 October 2015. This draft bill planned to relax the taxation of certain categories of outbound and inbound dividends in order to comply with European Union (EU) law. However, the proposals
See MoreArgentina-Double Tax Treaty with Switzerland enters into force
The new Double Taxation Treaty between Switzerland and Argentina will enter into force on 27 November 2015. The new treaty will be applicable from 1 January 2015. For taxes withheld at source the relief has become applicable from 2015. The new
See MoreRomania: Proposed reduction of dividend tax from 2016
The Romanian government is planning to cut dividend tax from 2016. At present dividend payments are taxed at 16%. This rate will be reduced to five percent from January 1, 2016, rather than from January 1, 2017 as previously planned. The
See MoreBulgaria: Draft bill to amend tax laws for 2016
The Council of Ministers has approved the bill for amendments to tax laws for 2016 and submitted the draft on 13th October 2015 to the parliament for consideration. The major improvements are as follows: Dividend withholding tax: Implementation of
See MoreThailand: Tax incentives for international headquarters
To promote the location of headquarters in Thailand the Board of Investment has introduced a new program. According to the program there will be relief from corporate income tax (0% on non-Thai source income from services, royalties, and dividends,
See MoreAustria: 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
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