US: Budget for 2016 Proposes Minimum Tax on Foreign Income and One-Time Tax on Profits Stockpiled Offshore
The US Government has proposed minimum tax on foreign income and one-time tax on profits stockpiled offshore in its 2016 fiscal budget. The minimum tax on foreign earnings is intended to reduce current incentives to trace production overseas and
See MoreRussia: Draft law on the thin capitalization rule submitted to State Duma
The Draft Law No. 675906-6 regarding the introduction of changes to article 269 of part 2 of the Tax Code in respect to the meaning of the concept of controlled indebtedness has been submitted to the State Duma on 16th December 2014. A
See MoreAnnual Conference of the Green Growth Knowledge Platform
The third annual conference of the Green Growth Knowledge Platform was held on 29 to 30 January 2015 with the theme Fiscal Policies and the Green Economy Transition: Generating Knowledge – Creating Impact”. Topics discussed at the conference
See MoreTransfer Pricing Brief: January 2015
Australia Requirement for Transfer Pricing Documentation- Taxpayers with a high risk transfer pricing profile will be held to more stringent requirements. Transfer Pricing Audits Penalty in Cases of Adjustments-25% penalty applies
See MoreRwanda: IMF Recommends Broader Tax Base rather than Higher Taxes
The IMF managing director visited Rwanda for three days from 26 January 2015 and a press release has been issued in respect of the IMF’s involvement in the country. Rwanda has enjoyed strong economic growth for fifteen years and is making progress
See MoreNigeria: Public notice of new filing rules for non-resident companies
The Federal Inland Revenue Service (FIRS) has issued a public notice in accordance with section 55 of the Companies Income Tax Act (CITA) on 28th January 2015 requiring all resident and non-resident companies to file their tax returns on a real
See MoreChile: Special income tax regime for small taxpayers
Provided by article 14 of the Income Tax Law (LIR) as amended by Law 20,780, the tax administration of Chile has released “Circular letter 69” on 6th January 2015 that gives the administrative interpretation of the new special income tax regime
See MoreEcuador: introduces anti-abuse provision on loans to shareholders
Under new legislation loans made by Ecuadorian companies to non-resident shareholders are treated as dividends and therefore subject to Ecuadorian withholding tax. The applicable domestic withholding tax rate on dividends is limited to the
See MoreEcuador: Changes to corporate income tax
Generally Ecuadorian companies are subject to a 22% rate of corporate income tax. In accordance with the new law, if more than 50% of the company is owned by non-resident shareholders that are resident in “tax haven” jurisdictions, the
See MoreEcuador: Changes to capital gains tax
The tax reform in Ecuador includes measures regarding the taxation of capital gains related to indirect and direct transfers of shares of Ecuadorian corporations with increased rates of corporate tax imposed on shareholders of Ecuadorian
See MoreLatvia: Budget committee approves 9% Microenterprise tax rate
The Parliament Budget and Finance (Taxation) Committee approved in principle a draft bill which sets the micro-enterprise tax rate at 9% in the first three years since the company's registration. As reported, in 2015, the tax rate for
See MoreSpain: Modifies the transfer pricing legislation
In the “Corporate Income Tax Reform 2015” enacted under the Law 27/2014 the following transfer pricing rules are amended; Scope of related-party transactions - The ownership requirement for related parties is increased from 5% (1% in the
See MoreHong Kong: IRD Releases Revised Forms To Apply For Resident Status For Tax Treaties
The Inland Revenue Board of Hong Kong on January 29 released revised forms for companies, partnership, trusts, and other entities to apply for a certificate of resident status for purposes of claiming tax treaty benefits. With effect from 1 February
See MoreRussia: Federal Arbitration Court has made decision regarding tax audits of adjusted tax returns
A Russian company naming “OJSC RN Holding (OJSC)” has submitted adjusted tax returns for June, August and December 2009 to the tax authority and claimed a reduction of the excise tax liability paid upon excise good’s importation to Russia.
See MoreFinland: Tax Administration Publishes Guidance On Advance Tax Withheld On Dividend
Finish Tax Administration published guidance, on 26 January 2015, on advance tax withheld on dividends paid to resident natural persons and estates of deceased persons. The guidance named “Guidance No. A14/200/2015 of 22 January 2015” specifies
See MoreRomania: Government Plans To Cut VAT Rate In 2016
The Romanian Government is planning to cut the value-added tax rate by 3% from 2016. The announcement marks a part reversal of the VAT hike introduced in 2010, to 24 percent from 19 percent. Romania’s Prime Minister Victor Ponta said that either
See MoreEl Salvador: IMF Country Report on Fiscal Policy
The IMF issued Country Report 13/15 on El Salvador on 12 January 2015, following the completion of an IMF mission to El Salvador to assess the country’s economic situation. To deal with the imbalances in the pension system the IMF recommends a
See MoreChile: Tax reform implications for foreign investors
Foreign investors in Chile require to consider the effect of tax reform changes. According to the prior tax regime, Chile had a combined tax system whereby the corporate income tax paid by the Chilean entity was added to the foreign shareholder tax
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