Luxembourg: New circular declares VAT exemption for risk management services
“Administration de l’Enregistrement et des Domaines”, the Luxembourg VAT Authorities issued a Circular (Circular n° 723 ter) on 7th November 2013, confirming that risk management services for funds could be VAT exempt. The guidance from the
See MoreLuxembourg wants acceleration of negotiation on Savings Tax
Luxembourg has called on the European Commission (EC) to accelerate negotiations with third party countries, to make sure that progress is made on plans to modify the Savings Tax Directive. The Savings Tax Directive is designed to ensure that income
See MoreLuxembourg Considers Tax Rise
The assessment of current negotiations on the formation of a new Government of Luxembourg is that there is a pledge to redressing the public finances if necessary with recourse to tax measures. However Luxembourg is starting from a favorable
See MoreIreland: Tax hike hits Irish savings
According to one well known financial institution (the Nationwide Building Society), the Irish Finance Minister has decided to raise the Deposit Interest Retention Tax (DIRT) and it represents a very bad news for Irish savers. The extent of
See MoreHungary- Amendments to Corporate Law
Hungary is going to modify its civil code by making significant changes to the corporate law which is likely to become effective from March 2014. According to the amendments, new companies may be permitted to establish their own company guidelines
See MoreFrance – reform to the tax procedure of life insurance contracts
The French Ministry of Finance presented the year-end supplementary finance bill of 2013 to the Council of Ministers. The bill comprise of plans to reform the tax procedure of life insurance contracts. The ministry is planning to increase the rate
See MoreRussia–Readjusting the taxable base for transfer pricing purposes may impact on the VAT base
The Russian Ministry of Finance has made public Letter No. 03-01-18/19214 clarifying the rights of tax authorities to readjust the taxable base in the case of selling goods and performing of works or services between related parties. Article 105.3
See MoreRussia – 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
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