Sweden: Tax Authority releases updated guidance on hard-to-value intangibles
On 13 September 2018, the Swedish tax authority published an update of transfer prices guidance on intangible assets consistent with OECD's difficult-to-measure intangible assets (HTVI) guidance. The OECD HTVI Guidance offers tax authorities with a
See MoreUS: IRS publishes draft form regarding the “base erosion and anti-abuse tax” (BEAT)
On 5 September 2018, the United States (US) Treasury and the Internal Revenue Service (IRS) released a draft of Form 8991 concerning the “base erosion and anti-abuse tax” (BEAT) reporting for 2018. In an effort to " level the playing field
See MoreBrazil: Administrative Council of Tax Appeals approves validity of resale price method (PRL 60)
The Administrative Council of Tax Appeals (CARF) issued binding decision 115 (Súmula no. 115) on 11 September 2018. The new decision approving that, the calculation method of the ' 60% Profit Price Less Profit Method (PRL 60)' provided for in
See MoreIMF Comments on Austria’s Fiscal Position
On 12 September 2018 the IMF issued a report following the conclusion of consultations in Austria under Article IV of the IMF’s articles of agreement. Austria’s economic recovery is broad-based with output expanding by 3% in 2017, boosted by
See MoreIMF Report Comments on Russia’s Economy
On 12 September 2018 the IMF published a report following consultations in Russia under Article IV of the IMF’s articles of agreement. The economy is recovering from the recession of 2015–16 owing to an effective policy response combined with
See MoreKazakhstan: Resolution No. 528 of 27 August 2018 publishes for amending APA process
According to Resolution No 528 of 27 August 2018 published on 6 September 2018, the review committee must complete its review within 60 working days of receipt of the application. If the application is approved, the signed contract should be sent to
See MoreBulgaria: Consultation on draft Law for implementing EU ATAD
The Finance Ministry is consulting on draft legislation for the execution of certain measures of the EU Anti-Tax Avoidance Directive (ATAD). A new interest limitation rule was proposed in this draft Law. This new rule would restrict the amount of
See MoreIMF report looks at fiscal policy in Latvia
On 6 September 2018 the IMF issued a report following the conclusion of discussions with Latvia under Article IV of the IMF’s Articles of Agreement. Economic growth rose in 2017 owing to increasing wages, recovery of private investment and faster
See MoreTurkey: Finance and Treasury Ministry increases interest rates for late payment tax
The Ministry of Finance and Treasury published a Decree No. 62 on September 5, 2018, in the Official Gazette. This Decree contains increase in monthly interest penalty for late payment taxes from 1.4% to 2.0%. Again then on September 6, 2018, a
See MoreSweden: Government announces a legislative proposal to amend the CFC rules
On 4 September 2018, The Swedish government published a legislative proposal to amend the country's controlled foreign company (CFC) rules to comply with the EU Anti-Tax Avoidance Directive (ATAD1). Under the CFC rules, income of foreign entities
See MoreGreece: Prime Minister announces some amendments in tax legislation
The Prime Minister, Alexis Tsipras, announced on September 8, 2018, plans for tax cuts and pledged spending to heal years of painful strictness, less than a month after Greece emerged from a bailout program financed by its European Union partners
See MoreIsrael: Tax Authority publishes Circulars regarding transfer pricing issues
The tax authorities (ITA) have recently published final versions of two professional Circulars, entitled Circular 11/2018 and Circular 12/2018, stating the ITA's expected profit levels for marketing services and for low-risk distributorship
See MoreIreland announces corporation tax roadmap
On 5 September 2018, the Minister for Finance and Public Expenditure & Reform, Paschal Donohoe T.D., has published Ireland’s Corporation Tax Roadmap. The Roadmap takes stock of the changing international tax environment, outlines the actions
See MoreUK: Proposed Cut to National Insurance Contributions Scrapped
On 6 September 2018 the UK government announced that the planned abolition of Class 2 national insurance contributions would no longer be carried out in this parliament. The UK government had previously announced that Class 2 national insurance
See MoreUS: Appeal Court Overturns Altera decision on stock based compensation in CSAs
On 24 July 2018 the US Court of Appeals overturned the decision of the Tax Court in the case of Altera Corp, a case that concerned the inclusion of stock based compensation costs in cost sharing agreements (CSAs). The Appeal Court has determined
See MoreUS: Appeal Court Rules in Favour of IRS in Medtronic Case
On 16 August 2018 a US federal appeals court vacated and remanded a 2016 decision by the Tax Court in the case of Medtronic v. Commissioner. The Court of Appeals ruled that in its original decision in favour of Medtronic the Tax Court did not
See MoreWorld Tax Brief: September 2018
Chile Business income taxation: On 21 August 2018, the Chilean president announced that a bill on tax reform would be submitted to Congress. The tax reform laws would propose a single integrated corporate tax system that would eliminate the
See MoreTransfer Pricing Brief: September 2018
Australia Special rules for hybrid instruments or entities: On 16 August 2018, Treasury Laws Amendment (Tax Integrity and Other Measures No. 2) Bill 2018 containing the hybrid mismatch integrity measures was passed by the Parliament. The bill
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