Ukraine: 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
See MoreRussia: 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,
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