Transfer Pricing Brief: November 2013
Australia Under Draft Taxation Determination TD 2013/D3 support payments made by an Australian parent company to a foreign related entity would be considered as capital payments and would not be tax deductible for the Australian parent.Profit
See MoreVietnam – Changes to tax administrative penalty rules
Vietnam’s tax authorities have issued a decree that amends the rules that apply with respect to penalties assessed for tax administrative violations. Decree 129/2013/ND-CP (16 October 2013) revises the tax administrative penalty rules. Among the
See MoreVenezuela – Foreign currency rules regarding import objectives
The decree regardingthe share of foreign currency used for import activities has published in official gazette N° 40.259 and will be effective from September 26, 2013. This contains changes to the rules and authorization procedures for gaining
See MoreUSA – IRS Announces Pension Plan Limitations for 2014
On October 31, 2013, the Internal Revenue Service announced cost of living adjustments affecting dollar limitations for pension plans and other retirement-related items for tax year 2014. Some pension limitations such as those governing 401(k)
See MoreUSA – Inflation Adjustments for 2014
On October 31, 2013, the Internal Revenue Service announced annual inflation adjustments for the year 2014 for more than 40 tax provisions, including the tax rate schedules, and other tax changes. Revenue Procedure 2013-35 provides details about
See MoreUruguay – Guidance on tax implications of fees paid to foreign companies
The tax administration of Uruguay issued guidance on 29 October 2013 about the applicability of Uruguay’s non-resident income tax and value added tax (VAT) on payments of certain fees paid to foreign companies. According to the guidance foreign
See MoreUK Considering Tax For Foreign Property-Buyers
The UK Chancellor of the Exchequer refused to confirm reports that the Government is considering moves to impose Capital Gain tax on foreign investors for property sales in Britain, as a measure to control property prices in London. At present,
See MoreUK Energy Firms Allegedly Using a Loophole To Cut Tax Bills
Several UK energy companies were accused on 30 October 2013 for abusing a legal loophole with a view to cut their tax bills. It was revealed by The Independent newspaper and Corporate Watch research that more than 30 UK businesses have been
See MoreSwitzerland: Budget Surplus despite Revenue Dip
The Swiss Federal Department of Finance released that the Confederation is forecasting the excess budget of this year CHF0.3bn (USD0.33bn) on 1 November 2013. Switzerland’s budget presented for a shortage of CHF0.4bn in 2013. Revenues are expected
See MoreSpain: Tax ruling expanding capital gains tax to indirect transfer of Spanish real estate by Luxembourg entities
Spanish tax authority recently published a ruling regarding indirect transfer of Spanish real estate by a Luxembourg entity which is taxable in Spain under the provisions of the Luxembourg-Spain tax treaty. Investment funds from real estate and
See MoreSpain: National budget bill 2014
National budget bill of Spain for 2014 was presented on 30 September 2013 in the Spanish Parliament. The 2014 draft budget has proposed an amplification of the surcharges for 2014. On the other hand, it has been also raised to hold the Wealth Tax
See MorePortugal: Lower tax burden in 2015
The Finance Minister of Portugal has indicated that the Government is aiming to reduce the tax burden on workers in Portugal within the framework of the 2015 State Budget (OE 2015). The State Budget 2014 of Portugal is designed to redress the public
See MorePortugal: Budget VAT announcements
The draft VAT Bill 2014 of Portugal contains a range of amendments to the Portuguese VAT rules. According to the draft amendments, VAT on irrecoverable debts may only be refunded within two years from the beginning of the fiscal year after the bad
See MoreOman: Clarification of tax rules
The Oman government has clarified that the tax rules in Oman require the following: Within three months from the date of incorporation or commencement of activities, taxpayers must be registered with the Omani tax authorities and if there is any
See MoreNew Zealand – Increase in the Family Tax Credit
The New Zealand Inland Revenue has announced that the minimum family tax credit will be increased starting from 1 April 2014. Low income families who work the minimum number of hours and who are not receiving a benefit will have an after-tax income
See MoreJapan: tax reform outline announced
The Japanese government has officially decided to increase the rate of consumption tax from the current 5% to 8% with effect from 1 April 2014. It has also delivered a five-trillion yen (US$50B) economic stimulus policy that aims to alleviate
See MoreIsrael: Action required for releasing trapped profits by 11 November 2013
Only those companies have to apply the temporary partial relief from Israeli corporate income tax until 11 November 2013, who wish to release their trapped exempt profits that were accrued until December 31, 2011. Companies will have to submit their
See MoreIndia : Loan simplification services and fees of foreign branches
In a recent decision, the Mumbai Bench of the Income-tax Appellate Tribunal found that: Services provided by a taxpayer bank were “crucial services” and the services were not a “mere facilitation” for concluding or signing of the loan
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