Transfer Pricing Brief: September 2015
Ukraine: Comparable uncontrolled price method (“CUP”): As per the new law which came into force from August 11 2015, taxpayers are allowed to use Comparable Uncontrolled Price (“CUP”) method only with reference to the prices on the
See MoreWorld Tax Brief: September 2015
Australia Sanctions for tax evasion: The Government of Australia announced double the maximum administrative penalties that can be applied by the Commissioner of Taxation to large companies that enter into tax avoidance and profit shifting
See MoreRussia: Wheat export duty amended
The Russian Government has amended the method for calculating wheat export duty that was in force from 1st July 2015. The government has increased the deductible portion of the wheat export duty from 5,500 rubles ($83.9) to 6,500 rubles ($99.1)
See MoreSpain: Partial amendments of general tax law
Spain has published the official Gazette regarding partial amendments of general tax law which was amended on 22 September, 2015 as a Law no.34/2015. The Law will enter into force on 12 October 2015 except for the obligation to keep specific
See MoreNew Zealand: Inland Revenue revises its guidance on APA
Inland Revenue recently updated its guidance on the Advance Pricing Agreement (APA) application process and published a list of steps aiming to standardize the process. Agreements can be required from Inland Revenue alone (unilateral) or between
See MoreFrance: Draft Finance Bill 2016
The draft Finance Bill for 2016 has been presented in France. According to the proposals the income tax-exempt threshold will be increased to EUR9,700 (USD10,840). For income above this threshold the income tax rates will be reduced. The tax rates
See MoreLatvia: Government planning to introduce solidarity tax
Latvian Finance Ministry recently declared a draft law regarding a new tax for high earners, to make the nation's flat tax regime more progressive. From 1 January 2016, employees earning over EUR 48 600 a year will pay a 4% solidarity tax on the
See MoreAFRITAC discusses prevention of tax fraud
From 28 September to 2 October 2015 the IMF’s regional Technical Assistance Centers (AFRITAC) for central and southern Africa are holding a seminar on prevention of tax fraud. The seminar held in Mauritius in collaboration with the African
See MoreEgypt- Reduced Tax Rates published in the Official Gazette
Decree Law No. 96 for 2015 amending Income Tax Law No. 91 for 2005 was published in the Official Gazette No. 24.bis for 2015 on 20 August 2015. The main changes are summarized below: 1) The standard corporate tax rate is reduced from 25% to 22.5%
See MoreIMF: Report on fiscal policy of Sweden
The IMF has published on its website the concluding report by staff after consultation with Sweden under Article IV of the IMF’s articles of agreement. The IMF report indicates that Sweden’s economy is performing well and economic growth should
See MoreItaly: Published Legislative Decree on Transfer Pricing Issues in the Official Gazette
Italy Published Legislative decree n. 147 in the official gazette on 22 September 2015 with a view to provide investors with certainty arising from their investment plan. As per the published Legislative decree, expenses relating to the transactions
See MoreThailand: Tax incentives for international headquarters
To promote the location of headquarters in Thailand the Board of Investment has introduced a new program. According to the program there will be relief from corporate income tax (0% on non-Thai source income from services, royalties, and dividends,
See MoreColombia: National Tax Authority Issued Transfer Pricing Rules on Sales of Intangibles
The National Tax Authority of Colombia announced on sale transactions of intangibles subject to the transfer pricing regime. In article 260-1 of the Tax Code provides criteria for ascertaining whether two or more parties are related parties and the
See MoreAustralia introduced multinational anti-avoidance law, CbC reporting and increased penalties
The Treasurer of Australia introduced a Bill to implement the announced multinational anti-avoidance law to apply to foreign multinationals generating certain profits earned from Australia without an Australian permanent establishment;
See MoreUS: IRS Released Temporary Regulations to Clarify that the Arm’s-Length Standard of Section 482 Applies to all Controlled Transactions
IRS issued Treasury Decision 9738 on 14 September 2015 containing temporary regulations under Section 482 clarifying the application of the arm’s-length standard when multiple code sections. The temporary regulations apply to tax years ending on
See MorePoland: Parliament approves new R&D tax incentives
The parliament accepted a bill proposed by the former president amending the Corporate Income Tax Law to establish new research and development (R&D) tax incentives and promote modern technologies, on 25 September 2015. According to the bill,
See MoreLithuania issues a proposal to amend the Law on Corporate Income Tax
The Ministry of Finance of Lithuania issued a proposal to amend the Law on Corporate Income Tax on 3 September 2015. If approved by parliament the amendments will enter into force on 31 December 2015. Under the proposed amendments, anti-abuse rules
See MoreDenmark publishes information on the Budget for 2016
The Danish government published information on the Budget for 2016 on 29 September 2015. The tax measures set out in the Budget, which will be presented to the parliament on 8 October 2015, include some important changes as summarized below: -
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