US: IRS Issues Notice 2015-54 Limiting Ability to Transfer Property to a Partnership Tax Free
The IRS and Treasury published Notice 2015-54 on August 6, 2015 modifying the rules applicable to the contribution of built-in gain property to a partnership. Under the Notice, a U.S. transferor is required to recognize any built-in gain on the
See MoreUS Treasury to develop regulations implementing CbC reporting requirement
US Treasury announced on 31 July 2015 that the US government intends to develop regulations implementing the OECD/G20 base erosion and profit shifting (BEPS) action plan guidance on country-by-country (CbC) reporting by multinational
See MoreGhana: Tax Authority Formed Special Tax Compliance Taskforce
The revenue authority of Ghana has formed a special revenue collection taskforce including 40 members. The aim of taskforce is to enforce compliance with the country's tax code and to encourage actual or potential tax defaulters to honor their tax
See MoreChile: Taxation of foreign investors and change of residence
The tax authority in Chile has issued Circular No. 1985 in relation to the taxation of Chilean-sourced investment income of foreign investors. The Circular explains the responsibility of the foreign investor to advise any change of residence to
See MoreSlovak Republic: VAT rate on meat products reduced
Slovakia cut 10% VAT rate on fresh meat products from the standard rate of 20%. Hopefully, this new rate will entry into force from 1st January
See MoreUK: HMRC comments on reduced VAT rate for installation of energy saving materials
On 31 July 2015 the UK tax authority HMRC published Revenue and Customs Brief 13 (2015) on the reduced rate of VAT on the installation of energy saving materials. The European Commission commenced proceedings in the European Court of Justice as in
See MoreKazakhstan: President signs a Law on pensions
The President has signed a law on 4th August 2015 to amend the process of obligatory pension contributions and budget funded state pension payments. The main amendments are given below: Employers Employers are obliged to withhold from salary and
See MoreCyprus and Iran sign Income Tax Treaty
The Republic of Cyprus and the Government of Iran signed an Income Tax Treaty on August 4, 2015 for the Avoidance of Double Taxation. The treaty will come into force after the two countries exchange ratification instruments. Under the treaty, the
See MoreIMF comments on fiscal and tax policy in Kazakhstan
The International Monetary Fund (IMF) has concluded discussions with Kazakhstan under Article IV of its articles of association and on 5 August 2015 a report was issued commenting on Kazakhstan’s economic situation and fiscal policy. Real GDP
See MoreIMF report contains tax recommendations for the UAE
The International Monetary Fund (IMF) has concluded discussions with the United Arab Emirates (UAE) under Article IV of its articles of association and on 4 August 2015 published a report and a selected issues paper. The IMF notes that government
See MoreUkraine: State Fiscal Service published letter regarding tax control over transfer pricing
The State Fiscal Service (SFS) published Letter No. 24525/7/99-99-22-01-02-17 issued on 7 July 2015 addressing the penalties levied for failure to submit transfer pricing (TP) documentation or to include relevant information about controlled
See MorePoland: Amending bill adopted by government
The Council of Ministers adopted a bill amending the Corporate Income Tax Law and Individual Income Tax Law on 21 July 2015.The amending bill requires a taxpayer that is part of a multinational corporate group with annual income or expenses of at
See MoreChina: Announcement on Cost Sharing Agreements
Recently, China’s State Administration of Taxation has promulgated the Announcement on Standardizing the Administration of Cost Sharing Agreements (the "Announcement 45") for implementation as of July 16, 2015. This announcement 45 is issued to
See MoreChile: Guidance on statement needed to benefit from a tax treaty
The Internal Revenue Service has issued Resolution No. 48 along with instructions on 25th May 2015 regarding the contents of a confirmed statement to be requested by a Chilean payer from a beneficiary resident in a tax treaty country due to apply
See MoreCanada: Draft legislation released implementing events from Economic Action Plan 2015
The Finance Minister has published draft legislative proposals on 31st July 2015 that would implement certain tax measures from the Economic Action Plan 2015 including: Amending the frequent failure report of income penalty to apply only for a
See MoreWorld Tax Brief: June to July 2015
Austria Withholding tax on dividend distributions, capital gains: The withholding tax rate for dividends and capital gains will be increased to 27.5% (up from the current rate of 25%). If dividends are paid to corporations, a reduced withholding
See MoreCanadian parties announce election campaigns
The Prime Minister of Canada has declared election campaign for his party with a statement that the Internship Job Creation Tax Credit will be improved. The federal general election will go on 19th October
See MoreTransfer Pricing Brief: July 2015
India: Comparable data range: The Punjab and Haryana High Court confirmed a judgment in the case of CIT-I v. DSM Anti Infectives India Ltd. ITA No. 116 of 2014 of a tax appellate tribunal that certain companies could be appropriate
See More