Argentina: New Regulations ‘General Resolution 4094-E’ enters into force
The Federal Tax Authority (FTA), on July 18, 2017, published the General Resolution 4094-E on the Official Gazette. This Resolution had been introduced into income tax in 2013. The time when the 2013 tax reform abolished the capital gains tax
See MoreGreece: Draft law regarding TP documentation requirements for CbC reporting
The Parliament of Greece introduced a draft Law 4484/2017 on July 20, 2017 that amends to the Corporate Income Tax Law L.4170 / 2013 and 4474/2017. The suggested amendments contain additional transfer pricing documentation requirements corresponding
See MoreIndia: Physical presence in the source state is not necessary to constitute a service PE
A recent decision of the Bengaluru Bench of the Income-tax Appellate Tribunal (Tribunal) in the case of: ABB FZ-LLC v. DCIT [ITA(TP) No. 1103/Bang/2013, assessed the India-UAE (United Arab Emirates) Double Taxation Avoidance Agreement (tax treaty)
See MoreUK: Updates on Finance Bill (No. 2) 2017
On 20 July 2017, the UK government tabled resolutions for the Finance Bill (No. 2) 2017. The government has now published explanatory notes on resolutions, which give a brief description of each of the Finance Bill resolutions. The Finance Bill (No.
See MoreNetherlands: The Dutch government publishes consultation on anti-tax avoidance directive
The State Secretary of Finance provided a letter to Dutch parliament in which he indicated that an internet consultation has been opened for a draft bill on 10th July 2017. The draft bill has been formulating in order to implement the first EU
See MoreCzech Republic: Chamber of Deputies passes legislation to implement CbC reporting
The chamber of deputies approved a legislation that implements a new information exchange duty, i.e. country-by-country (CbC) reporting into Czech legislation. The legislation will be effective when all legislative and processes are done. According
See MoreCyprus: Tax Authority issues guidance on revised transfer pricing framework
On 30 June 2017, the Cyprus Tax Authorities (CTA) published a Circular revising the transfer pricing framework for companies carrying out intra-group financing activities in Cyprus. The Circular defines intra-group financing transactions as all
See MoreItaly: Revised transfer pricing rules
Decree No. 50 published on 24 April 2017 was implemented on 15 June 2017. According to Article 59 of Decree Law No 50/2017, a corresponding downward adjustment leading to a lower taxable income will no longer be subject to a mutual agreement
See MoreUK: HMRC publishes statistics on creative industries tax relief
On 20 July 2017 HMRC published updated statistics on claims for creative industries tax relief. The statistics include data for film tax relief, high end television tax relief, animation tax relief and video games tax relief, children’s television
See MoreOECD: Revenue Statistics in Asian Countries
On 20 July 2017 the OECD published the latest edition of its publication Revenue Statistics in Asian Countries. This covers trends of revenue statistics in Indonesia, Japan, Kazakhstan, Korea (Rep), Malaysia, Philippines and Singapore between 1990
See MoreOECD updates guidance on country by country reporting
On 20 July 2017 the OECD published updates to the guidance on country by country (CbC) reporting requirements under Action 13 of the project on base erosion and profit shifting (BEPS). This guidance for tax administrations and multinational groups
See MoreUK: Impact of video games tax relief
Research has been conducted on behalf of HMRC to look at the impact of video games tax relief (VGTR) on the production of culturally British and European video games. The survey was conducted by holding qualitative in-depth interviews with 51 video
See MoreJapan issues guidance concerning customs valuation opinion
Japan’s customs bureau has recently issued guidance “customs valuation opinion” concerning how retroactive transfer price adjustments are to be addressed from a customs valuation perspective. The customs agency will consider adjustments as
See MoreItaly: Tax ruling on withholding tax exemption for foreign investments in real estate
The Tax Authority of Italy (Agenzia delle Entrate) has issued a tax ruling -Risoluzione n. 78/2017- on 27 June 2017. The ruling is related to certain foreign investment funds which wish to benefit from an exemption from withholding tax. The tax
See MoreCanada and EU: CETA agreement to enter into force
Recently the Prime Minister of Canada and the European Commission announced that they were agreed that the Canada-European Union Comprehensive Economic and Trade Agreement (CETA) would enter into force on September 21, 2017. The CETA will create
See MoreThailand: Consultation process of the draft Transfer Pricing rules
The Revenue Department of Thailand is requesting public comments with respect to the Draft Transfer Pricing Rules which were approved by the Thai Cabinet on May 2015. The comments are to be provided by 7 July 2017. Recently, the draft measures were
See MoreGermany releases guidance on CbC reporting requirements
The Germany Federal Ministry of Finance on 11 July 2017 issued guidance on the Country-by-Country (CbC) reporting requirements in line with BEPS Action 13 and the EU Administrative Assistance Directive as amended. The guidance clarifies the
See MoreBrazil: Tax authority issues a ruling on tax rates for reinsurers
The tax authority of Brazil has issued COSIT Consultation Response no. 62/2017 (Solução de Consulta n. 62/2017) setting out views of the General Office to Coordinate Taxation (COSIT) on tax rates applicable to reinsurers. The Consultation
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