India: High Court affirms that comparables must be functionally similar
In the case of: CIT-I v. DSM Anti Infectives India Ltd. ITA No. 116 of 2014 the Punjab and Haryana High Court confirmed a judgment of a tax appellate tribunal that certain companies selected in a search for comparables in a transfer pricing analysis
See MorePakistan: Budget for 2015/16
The Budget for the fiscal year 2015/16 (tax year 2016) was presented on 5 June 2015. The Budget proposals will basically take effect from 1 July. The proposed measures are summarized below: Corporate Tax: The corporate income tax rate is to be
See MoreKenya: Finance Bill for 2015
The Finance Bill 2015 was presented to the National Assembly on 11 June 2015. The Bill contains far reaching improvements to different laws and regulations as well as introducing new tax laws. Corporate taxation The corporate tax rate for a
See MoreUK: New budget announcements for 2015/16
On 8 July 2015 the UK government announced a further set of budget proposals for 2015/16. This summer budget 2015 follows the general election and contains revisions and additions to the original budget proposals presented in March
See MoreHong Kong: Notes exchanged with Japan in relation to tax treaty in force
The agreement constituted by the exchange of notes between Hong Kong and Japan regarding the Exchange of Information Article of the Comprehensive Avoidance of Double Taxation Agreement between the two jurisdictions has entered into force on July 6,
See MorePoland: Published revised draft bill on transfer pricing documentation
Poland’s Government published the revised draft of the Personal Income Tax /Corporate Income Tax Act (Bill) concerning documentation of intercompany transactions on 18 June 2015. According to the revised draft, the management or control
See MoreNigeria: VAT exemption for basic food items
According to Nigeria’s tax law, basic food items are exempt from VAT. The Federal High Court (Lagos) of Nigeria has issued a decision concluding that packaged water is a basic food item and is exempt from VAT. The decision was issued on 11th May
See MoreRussia: Federal Council accepts amendments on CFC rules
The Russian Federation Council has accepted draft law, No. 714002-6 on 3rd June 2015 that contains changes to the Controlled Foreign Company (CFC) rules and the tax residency idea. It was signed by the President and officially published on 8th June
See MoreCanada: Corporate tax measures enacted
Bill C-59 has received its first reading on 7th May 2015 implementing certain measures announced in the 2015 federal budget. These measures will not be applicable until after the upcoming federal election expected in October 2015. The enacted
See MoreCyprus: Sweeping tax reforms to encourage foreign investors
Cyprus has announced a series of tax reforms which aim to sustain Cyprus as an even more attractive choice for Individuals and companies aiming to structure their worldwide investments using Cyprus as the jurisdiction of choice for holding
See MoreChina ratifies Multilateral Convention for Mutual Assistance in Tax Matters
On 1 July 2015 China’s National People’s Congress approved the signature of the Multilateral Convention for Mutual Assistance in Tax Matters. The agreement was originally signed by China in August 2013. The Multilateral Convention contains
See MoreTransfer Pricing Brief: June 2015
India: Intangible property: The Delhi High Court ruling on marketing intangibles in the Sony Ericsson Mobile Communications India Pvt. Ltd. case provides clear guidance on how the issue of marketing intangibles should be viewed in cases where
See MoreIndia: Delhi High Court Expresses Its View on Marketing Intangibles
Recently, the Delhi High Court issued its much anticipated ruling on marketing intangibles in the Sony Ericsson Mobile Communications India Pvt. Ltd. case. The High Court ruling is partially in favor of the taxpayers engaged in the import,
See MoreNigeria: ECOWAS common external tariff to be implemented
The Nigerian Customs Service has issued a circular on 23rd June 2015 for accepting the implementation of the Economic Community of West African States (ECOWAS) Common External Tariff (CET) 2015-2019. Benin, Burkina Faso, Cape Verde, Gambia, Ghana,
See MoreRussia: Convention on Mutual Administrative Assistance in Tax Matters enters into force
The Multilateral Convention on Mutual Administrative Assistance in Tax Matters has entered into force in regard to Russia on 1st July 2015. The Convention and the amending protocol apply to Russia from 1st January 2016. The agreement is intended
See MoreAustralia: tax cuts for small business
According to the Budget the government of Australia is to decrease the income tax rate for small companies to 28.5 per cent with an aggregated annual turnover of less than AUD 2 million. Companies with an aggregated annual turnover of AUD 2 million
See MoreBangladesh: New Tax Provisions in Finance Bill 2015 Passed by Parliament
The Bangladesh Parliament passed the Finance Bill 2015 on June 29, 2015 with some changes in the tax provisions. The Finance Minister has increased the minimum amount of income tax for individuals residing in Dhaka and Chittagong. This year the
See MoreBangladesh: Changes in Transfer Pricing Provisions in Finance Bill 2015 Passed by Parliament
The Bangladesh Parliament passed the Finance Bill 2015 on June 29, 2015 with some changes in the transfer pricing provisions. The legislation relating to the report from an accountant required to be furnished by a person who has entered into
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