Belgian tax reform begin to emerge
In Belgium a consensus is arising that taxpayers should declare both their income from capital and income from labor in their income tax declaration. Advocates of this idea suggest that the income tax scale should be revised, to strengthen the
See MoreAustria: Research Institute Calls for Symbolic Cut in Taxes on Labor
The President of the Austrian Institute of Economic Research has urged the Government to launch its offensive on reducing the fiscal burden on labor in Austria as early as next year, starting with a symbolic first step. He proposed that the
See MoreAustria publishes revised draft bill amending tax acts
A revised draft bill of the 2014 Tax Amendment Act (Abgabenänderungsgesetz 2014; AbgÄG 2014) was forwarded to the Austrian Parliament on 29 January 2014. The revised draft bill modifies the initial draft bill with amendments to certain Austrian
See MoreGreece- Transfer Pricing Requirements regarding Financial Services and APA
The following requirements relative to financial services and Advance Pricing Agreement (APA) are described below: Financial Services: Financial services must follow the arm's length principle. It should also be noted that interest is deductible
See MoreUnited Kingdom – Tax compliance by suppliers under government contracts
The Cabinet Office has published a slightly revised version of the UK government’s procurement policy note, with measures to promote tax compliance. The note provides guidance on the government's policy on the use of the procurement process to
See MorePeru – Resolution changes withholding rate for VAT
On 1 February 2014 Peru’s tax administration issued a resolution concerning changes to the withholding rate for value added tax (VAT). This rate applies to the supplier, who must withhold the tax in respect of a transaction that is liable for VAT.
See MoreSlovenia – Constitutional Court Suspends Real Estate Tax
Slovenia's Constitutional Court has suspended property tax assessments. The tax imposes a charge based on property value of between 0.15 percent for occupied residences through to 0.5 percent for empty homes and 0.75 for commercial properties.
See MoreBrazil – Tax authority revises position on cross-border reimbursement arrangements
Brazil’s tax authority has issued a ruling to a taxpayer reflecting a change of position concerning cross-border cost reimbursement arrangements. Traditionally, the tax authority (Receita Federal do Brazil—RFB) has imposed a high tax burden of
See MoreBrazil – Ruling permits taxpayers to align their transfer pricing policies
According to a recent ruling by the Brazilian tax authority taxpayers should be able to better align their transfer pricing policies to eliminate potential contingent liabilities, reduce taxable adjustments, and/or eliminate the double taxation
See MoreSlovakia – Reduced corporate income tax rate
Slovakia’s Parliament has reduced the corporate income tax rate from 23% to 22% with effect from 1 January 2014. The reduced corporate income tax rate is effective for tax periods beginning after 31 December 2013. This change affects both the
See MoreNetherlands – Dividend withholding tax when companies located in Curaçao
The Advocate General of the Court of Justice of the European Union (CJEU) issued an opinion in two joined cases that involve profit distributions made by Dutch companies to their parent companies that are residents of Curaçao. The opinion of the
See MoreNetherlands – Distinction between loan interest and dividend
The Netherlands Supreme Court (Hoge Raad) on 7 February 2014 issued two decisions affecting taxpayers. The first decision related to whether a payment would be regarded as interest on a loan or as a participation dividend paid on a share capital
See MoreBelgium: Transfer pricing audits process
Likely high-risk targets for audits are highly leveraged companies, those with large tax losses carried forward, and those with fluctuating profits. Belgium has increased the number of transfer pricing audits and expanded the team of transfer
See MoreTransfer Pricing Brief: January 2014
Argentina From 3 January 2014 there is a monthly reporting requirement for certain domestic transactions on the Argentinian market using Form F968. France Draft legislation introducing a presumption that profits are received if functions and
See MoreWTO panel mediates US-Korea Trade Dispute
One of the important functions of the World Trade Organization (WTO) is to provide a means of settling trade disputes between its member states. The Dispute Settlement Body of the WTO established a panel on January 22, 2014 to mediate in a dispute
See MoreUS: Senate democrat leader opposes Trade Promotion Authority renewal
The US Senate Majority Leader has expressed his opposition to the Trade Promotion Authority (TPA), despite the intention of President Obama to engage with Congress to pass the legislation providing for the renewal of the TPA. This opposition to the
See MoreUS: Republican Obama Care Abolition Plan Includes New Tax Credit
The recent healthcare reforms of the Affordable Care Act, known colloquially as Obama care, have been vehemently opposed by some sections of the US Congress. Three United States senators have now released a legislative outline of how the Republican
See MoreUS: publication on foreign tax credit for individuals
The US Internal Revenue Service (IRS) has released the 2014 revision of Publication 514 (Foreign Tax Credit for Individuals). The publication of 24 January 2014 is intended for use in preparing 2013 tax returns. Publication 514 explains the
See More