Brazilian CFC rules apply despite treaties
The Federal Administrative Council of Tax Appeals (Conselho Administrativo de Recursos Fiscais, CARF) decided on 14 March 2017 that taxation in Brazil of profits of indirect controlled foreign companies (CFCs) under CFC rules is not prevented by tax
See MoreIndia: Delhi High Court removed the penalty assessment for related-party transactions
The Delhi High Court, in the case of: Pr.CIT v. Mitsui Prime Advanced Composites India Pvt. Ltd. (ITA 913/2016, CM APPL.46519/2016), dismissing tax department’s appeal and upheld the Tribunal’s order deleting penalty under Section 271(1)(c) of
See MoreNew Zealand releases consultation paper on interest limitation rules
The Finance and Revenue Minister released a consultation document regarding BEPS – Strengthening interest limitation rules and also inviting public submissions on proposals to improve New Zealand's thin capitalization rules on 3rd March 2017. The
See MoreSingapore, Luxembourg Competent authority agreement on automatic exchange of information signed
The Competent Authority Agreement on Automatic Exchange of Information (2016) between Singapore and Luxembourg was signed on 10 March 2017. The agreement provides details of what types information will be exchanged and when, in accordance with OECD
See MoreSingapore, Denmark Competent authority agreement on automatic exchange of information signed
The Competent Authority Agreement on Automatic Exchange of Information (2016) between Singapore and Denmark was signed on 13 March 2017. The agreement provides details of what types information will be exchanged and when, in accordance with OECD
See MoreCanada: The budget 2017–18 for Alberta issued
The Minister of Finance of Alberta presented the province’s fiscal budget 2017-18 on 16th March 2017. The budget includes no new taxes, and no tax increases or decreases that had not been announced previously. The general corporate income tax rate
See MorePanama deposits instrument of ratification for convention and protocol on mutual administrative assistance in tax matters
Panama deposited its instrument of ratification for the multilateral convention on mutual administrative assistance in tax matters, as amended by the 2010 protocol, on 16 March 2017. The Convention and the amending protocol will enter into force 3
See MoreTurkey: Reduction in stamp duty, deed fees and RUSF rates
The Decree 2017/9973 was published in the official gazette on 15th March 2017 that reduces stamp duty, deed fees and Resource Utilization Support Fund (RUSF) rates on certain transactions. The Decree entered into force on the day of its publication.
See MoreCanada: SMEs want tax cuts at Budget 2017
The Canadian Federation of Independent Business (CFIB) is Canada’s largest association of small and medium-sized businesses. The CFIB has published its list of recommendations for the upcoming federal budget 2017. The recommendations for the
See MoreBrazil publishes Normative Instruction 1,700/2017 in the Official Gazette
Decree No 2017-22042 of 7 March 2017 fixing the market interest rates for interest-free liabilities have been published in Official Journal No 15371 on 17 March 2017. The Decree upgrades and replaces Decree no. BLKB2015 / 1650M of 10 December 2015
See MoreChina concludes first cost sharing agreement APA
The State Administration of Taxation (SAT) of China recently concluded the first advance pricing agreement (APA) for a cost sharing agreement (CSA) with a Fortune 500 enterprise in Guangdong Province. The CSA-APA focuses on international R&D
See MoreGreece: Some important amendments on draft bill sent
An amendment regarding the draft bill, which amends the Income Tax Code and other provisions was submitted to the Greek parliament on 16th March 2017. The amendment states to the tonnage tax payment and the NAT special levy of category A
See MoreSerbia: Ministry of Finance publishes rulebook on arm’s length interest rates for 2017
The Serbian Ministry of Finance adopted the amendments to the Rulebook on arm's length interest rates (the Rulebook) on 10 March 2017. The rulebook contains the prescribed interest rates for taxpayers who had or will have related-party financing
See MoreGhana: Parliament Approves the Budget for 2017
The Parliament approved the Budget for the 2017 financial year after six days of fierce debate on it between the Majority and Minority sides. The budget which was the first one for the New Patriotic Party (NPP) government since assuming power on
See MoreSweden publishes regulation on automatic exchange of CbC reporting
The regulation on the automatic exchange of country-by-country (CbC) reporting (the Regulation) was published in the Official Gazette on 14 March 2017. The law proposal had been adopted on 1st March 2017. The Regulation, which will enter into force
See MoreJamaica extended the income tax return filing deadline
Jamaica’s tax administration has announced the deadline to file final income tax returns for the year of assessment 2016 n 15 March 2017 and the estimated returns for the year of assessment 2017 has been extended until 25 March
See MoreG20 leader reserved on financial transaction tax prospects
In a statement made at the G20 summit in Baden-Baden on March 18, 2107, OECD Secretary-General Angel Gurria stated that the proposal would only succeed if “adopted by a large number of countries, including those that house the major financial
See MoreUK: Government Cancels Proposed Increase in Class 4 National Insurance Contributions
Following criticism within Parliament, the government has scrapped the increase in Class 4 national insurance contributions originally announced on 8 March 2017 as part of the budget measures. Class 4 national insurance contributions are payable by
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