ECJ: Advocate General’s opinion on whether units of a municipality can be taxable persons
The Advocate General of the European Court of Justice (ECJ) has delivered an opinion in the case of Gmina Wroclaw. The municipality of Wroclaw applied to the Polish Finance Minister on the issue of whether a budgetary unit of a municipality could be
See MoreUkraine: Cabinet of Ministers adopts new advance pricing agreement procedures
Ukraine’s Cabinet of Ministers published Resolution No. 504 on 25 July 2015 regarding conclusion of advance pricing agreements (“APA”) in respect of controlled transactions for transfer pricing purposes. The new Resolution replaces the former
See MoreCanada: Ontario surtax relief
The Canada Revenue Agency (CRA) has suggested to the Investment Funds Institute of Canada (IFIC) that its systems will not be updated until 10th August 2015 to enable it to calculate the tax relief due from a mismatch of a mutual fund
See MoreDenmark: National Tax Tribunal Decision on foreign exchange losses on sale of shares
The Customs and Tax Administration published National Tax Tribunal Case No. 122-0208149 on 30 June 2015. The Tribunal held that foreign exchange losses realized on the sale of shares of a subsidiary resident in another Member State are not
See MoreUkraine: Electronic VAT administration begins from August 2015
The President of Ukraine signed the Law on Amendments to the Tax Code of Ukraine concerning improvement of the administration of value added tax 643-VIII on July 28, 2015. The new electronic system will enter into force on August 1, 2015. The
See MoreAustria: Parliament and Federal Council approve Tax Reform Act 2015/16
The parliament (Nationalrat) and Federal Council (Bundesrat) approved the “Tax Reform Act 2015/16 (Steuerreformgesetz 2015/16)” with minor changes on 23 July
See MoreUK: Consultation on the taxation of termination payments
On 24 July 2015 the UK issued a consultation document in respect of the reform of income tax and national insurance on termination payments by employers. This follows a report from the Office of Tax Simplification on ways in which the complexity of
See MorePeru: Notice on certificates of residence for claiming Double Tax Treaty benefits
On 3 July 2015 the Tax Authority of Peru issued Notice 094-2015 specifying certificates of residence status for claiming Double Tax Treaty benefits. According to the Peruvian law withholding will be required when an expense is accrued or when a
See MoreRussia: Input VAT deductibility on imported goods
The Finance Ministry has issued letter no. 03-07-15/31200 on 29th May 2015 to clarify the deductibility of VAT input tax on goods imported into Russia if the taxpayer has received a hard copy of the electronic customs declaration from the customs
See MoreIndia: Delhi Tribunal allows use of multiple-year data for purposes of determining arm’s length price
In the case of DCIT v. Innodata Isogen India Pvt. Ltd. , the Delhi Bench of the Income Tax Appellate Tribunal upheld a decision of the Commissioner of Income Tax (Appeals) to allow the taxpayer to use multiple-year data in determining the arm’s
See MoreIndia: Transfer Pricing Adjustment For Interest-Free Loan to Related Party
Recently, the Income-tax Appellate Tribunal upheld an interest adjustment on a loan that the taxpayer advanced to a related entity In the case of: Soma Textile & Industries Ltd. v. ACIT. Here the tribunal found that the comparable uncontrolled
See MoreWTO announces extension of the Information Technology Agreement
The World Trade Organization (WTO) announced on 24 July 2015 that an extension of the scope of the Information Technology Agreement has been agreed by 54 major exporters of these products. The scope of the agreement will be extended to cover new
See MoreSri Lanka: Commissioner General of Inland Revenue publishes gazette on Transfer Pricing Regulations
The Commissioner General of Inland Revenue has published gazette no. 1907/26 dated 25 March 2015 on Transfer Pricing Regulations. It was made available on the Government Printer’s website on 27 May 2015. The gazette requires the taxpayer to
See MoreSpain: BEPS country by country reporting provisions enacted
The Spanish Ministry of Finance published Royal Decree 634/2015 of 10 July 2015 in the Official Gazette on 11 July, 2015. The Decree contains corporate income tax regulations including (BEPS) country by country reporting requirements in line
See MoreGreece: tax authorities issue circular to clarify transfer pricing regulations
The Greek tax authorities issued circular no. POL 1142/02.07.2015 dated July 2, 2015 to explain transfer pricing (TP) documentation issues raised in light of the new Income Tax Law no. L. 4172/2013 and Tax Procedures Code no. L. 4174/2013. The
See MoreNew guidance on Advance Pricing Agreements issued by Australian Taxation Office
The Australian Taxation Office released its revised policies and procedures for the Advance Pricing Agreements program on 23 July 2015. The updated guidance has been provided in the form of Practice Statement Law Administration PSLA 2015/4, which
See MoreUK: Consultation on extension of HMRC data gathering powers
On 22 July 2015 the UK tax authority HMRC issued a consultation document entitled “Tackling the Hidden Economy: Extension of Data Gathering Powers”. HMRC estimated that in 2012/13 the element of the tax gap caused by the hidden economy amounted
See MoreCzech Republic: VAT reverse charge extended
The VAT reverse charge for a range of agricultural crops has been extended by the tax office. The local reverse charge mechanism is a tool used to help prevent so-called missing trader VAT fraud. This is a fraud whereby criminals target the EU
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