Poland: 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,
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
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