Russia – Controlled transaction is classified as transactions within individuals
The Russian Ministry of Finance (MoF) has issued Letter No.03-01-18/38106 on September 16, 2013 that explains whether transactions with individuals should be treated as controlled transactions for the purposes of transfer pricing regulations.
See MoreRussia-Applicable fields for applying thin capitalization rules
The Ministry of Finance has published Letter No. 03-08-05/23521 regarding the applicability of the thin capitalization rules to interest payments made by a Russian company on a loan granted by a Russian bank issued on June 21, 2013. For example, a
See MoreFinnish Administrative Supreme Court Order to pay interest on refunds of withholding tax collection
According to the Finnish Supreme Administrative court decision, Finland tax authority must pay interest on refunds of withholding tax collected in contrast to the EU law. The interest rate imposed on withholding tax refunds varies annually. In the
See MoreEgypt: Forbidden Progressive Tax Plans
Recently, the Egyptian committee has forbidden plans to include an article in the country’s basic law providing that progressive taxation should serve as a basis for tax policy. From the 2011 uprising, Egypt has been planning the idea of
See MoreFrance – Arm’s length indemnification for unfair termination of contracts
In two court cases of France it was reported on 9 January 2013 that a failure to provide the required notice period with respect to a group restructuring may provide a cause of action for an award of compensation for unfair termination of a
See MoreFrance – Transfer pricing adjustments been recognized by the Appellate courts
The Administrative Courts of Appeal of France recently issued decisions affirming transfer pricing adjustments which are as follows: Lyon court of appeals The Administrative Appeals court in Lyon concluded that Frenchco exercised direction and
See MoreFrance – Administrative Court of Appeal of Paris denies use of secret comparables
The Administrative Court of Appeal of Paris gave its decision in Nestlé Entreprises v. Minister of Economy and Finances (No. 12PA00469) on 5 February 2013 concerning the use of secret comparables under the transfer pricing regulation, article 57 of
See MoreSwitzerland: Flat’s Tax support to SMEs
It was reported that SGV (Switzerland’s main trade association), represents small- and medium-sized enterprises (SMEs) in Switzerland, has accepted the decision of the Swiss Council of States to refuse the people’s initiative calling for an end
See MoreIndia: Determines arm’s length price of share transfers
The Income-tax Appellate Tribunal has held that the discounted cash flow method was preferable over the “yield” method or “net asset value” method for purposes of determining the arm’s length price of shares transferred to related parties.
See MoreSwitzerland: Tax burden remain stable in 2014
According to a media report, the Swiss Federal Department of Finance has issued its tax exploitation index for 2014 on 10 December 2013; it disclosed that the average tax burden in Switzerland will remain same in 2014, compared to 2013. On average,
See MoreChina: Financial sector faces issues on transition to VAT
In the transition to a value added tax (VAT) system, the financial services sector in China will need to consider certain issues.China’s Ministry of Finance suggests that- to a VAT system in China, modern principles of VAT would be applied. The
See MoreCzech Republic – Changes regarding tax and insurance premiums
In the Czech Republic, under changes that are effective in 2014, employers will need to ready new rules regarding the taxation and insurance premiums in respect of employees. Again, there are changes to the social and health insurance premiums for
See MoreChile- New Bill is proposed to limit taxation of Senior Citizens
The Finance Minister of Chile proposed a new bill on November 8, 2013 for limiting the amount of tax payable for senior citizens with low incomes. The measure is taken to help the poorer people of this nation. The bill states that if an individual
See MoreCanada -Partnership information return for 2013
The Canadian Revenue Agency (CRA) has issued revised guidance for partnership information returns (Guide T4068), Guide for the Partnership Information Return (T5013 Forms) for the year 2013. The Guide T4068 contains changes to the forms, schedules
See MoreCanada – Making Declaration of proposed tax changes in Ontario
The Finance Ministry in Ontario has declared proposed measures to increase the tax rate on “non-eligible dividends” of up to 3.9% which was effective from January 1, 2014. Other proposed measures would include: Certain research and development
See MoreCanada will balance budget in 2015 without raising taxes
The Finance Minister of Canada released economic and fiscal projections annual update on that reports that the government is on the right track to balance the budget in 2015 without raising taxes. The government desires to balance the budget without
See MoreBrazil established new tax accounting rules
A provisional measure was published in Brazil on 15 November 2013, to establish new tax accounting rules which rescinds the transitional tax regime method and establishes the new tax rules to align Brazil’s tax accounting rules with the current
See MoreBelgium: Royal Decree on tobacco tax rise
A draft Royal Decree, regarding tax rise on tobacco is approved by the Belgian Council of Ministers. As a result, the excise duty on cigarettes will be fixed at EUR 6.8914 (USD 9.2) per 1,000 pieces from 1 January 2014, and the special excise duty
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