ECJ: 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
See MoreSouth Africa Launches First Islamic Bond
South Africa launched sub-Saharan Africa's first Islamic bond, paving the way for issues by other countries in the region. National Treasury has announced that, following the entry into force of tax provisions for Islamic financing at the beginning
See MoreItaly: Withholding tax rate hikes on financial income.
Italian withholding tax rate hike on financial income from 20 percent to 26% has been effective from July 1, 2014. Italian savers has been imposed increased tax rate on interest, dividends and capital gains in the passes of governments which was
See MoreBrazil: Tax exemption to encourage Initial Public Offerings
On June 16 of 2014 the Ministry of Finance confirmed that the initial public offerings (IPOs) of smaller company’s investment will be cut from the capital gain tax by 15% and the capital gains tax will not have an effect on infrastructure
See MoreTaiwan Approves 45 Percent Top Income Tax Rate
Tax reforms passed in Taiwan include a 45% rate of income tax on incomes above TWD 10 million per annum. Also included in the reform is an increase in the basic income tax threshold to TWD 90,000 for single taxpayers and TWD 180,000 for married
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