UK: HMRC Clarifies Approach to Taxing Multinationals
The UK Parliament’s Public Accounts Committee is taking evidence on 11 February 2016 in relation to the tax affairs of multinational enterprises. In advance of the parliamentary hearing the UK tax authority HMRC has published a factsheet on its
See MoreNew Zealand: IMF selected issues paper looks at tax changes
A selected issues paper published on 8 February 2016 was prepared by IMF staff as background to consultations in New Zealand under Article IV of the IMF’s articles of agreement. The paper notes that New Zealand’s economy has performed well in
See MoreChile: Law to simplify structural tax reform of 2014 published
Law No. 20.899 was published in the Official Gazette on 8th February 2016. This Law simplifies the implementation of the tax reform 2014 in matters regarding provisions of the tax code, income tax and VAT, among others. Under the tax reform of 2014
See MoreUK: HMRC Publishes Statistics on Accelerated Payments Notices
The UK tax authority HMRC has noted in a press release of 8 February 2008 that more than GBP 2 million has been collected under the accelerated payments provisions. Under these provisions the users of tax avoidance schemes must pay tax up-front
See MoreECJ: preliminary ruling on interest on VAT refund
The European Court of Justice (ECJ) gave a preliminary ruling on 21 October 2015 in the Kovozber case. Reference had been made to the ECJ by the Regional Court of Kosice (Slovak Republic) for a ruling on the following issues: 1. Should the first
See MoreIMF report comments on tax policy of Sri Lanka
On 5 February 2016 the IMF released a report on the conclusion of discussions by its staff in Sri Lanka under Article IV of the IMF’s articles of association. The Sri Lankan economy has been performing positively and real GDP growth was 5.2% in
See MoreRomania: New rules enacted for transfer pricing documentation
As per the Order no. 442/2016 published by the National Agency for Fiscal Administration (ANAF) on February 2, 2016, “large taxpayers” engaged in transactions with related parties, having a total annual value determined by reference to the value
See MorePeru- New filing conditions and requirements for the tax year 2015 published
The tax authorities of Peru published Resolution No. 358-2015 in the Official Gazette on 30 December 2015. The Resolution establishes new filing conditions and requirements for the entities and individuals of the income tax return for tax year
See MoreEU Joint Transfer Pricing Forum meeting in February 2016
The next meeting of the EU Joint Transfer Pricing Forum (EU JTPF) is scheduled for 18 February 2016. The EU JTPF aims to provide tools for practical application of transfer pricing rules in the EU and ensure efficient transfer pricing
See MoreIMF Technical Note on introducing a GAAR
On 31 January 2016 the IMF issued a technical note on ensuring that a general anti-avoidance rule (GAAR) achieves its purpose. Many countries have either introduced a GAAR or are considering its introduction, which the objective of combating
See MoreTransfer Pricing Brief: January 2016
Norway: Base Erosion and Profit Shifting (BEPS) Related Compliance: General Rule for Country by Country (CbC) Reporting: The Ministry of Finance published a public consultation paper regarding country-by country reporting for tax purposes. As per
See MoreWorld Tax Brief: January 2016
Chile CFC Rule: Under the Circular 30 of the tax administration from 2016, the main aspects of the CFC rules are: A controlled foreign entity exist where a Chilean resident holds, directly or indirectly, more than 50% of the shared capital,
See MoreUK: Use and Impact of Venture Capital Schemes
On 3 February 2016 HMRC published a research study of the use and impact of the Enterprise Investment Scheme (EIS) and Venture Capital Trusts. The research examined the incentive effects on investors of the two schemes; the impact on the ability of
See MoreCanada: Tax measures regarding New Brunswick’s 2016 budget
The 2016-17 provincial budget of New Brunswick which was presented on 2nd February 2016. It includes measures as follows: The province’s rate of harmonized sales tax (HST) has increased from 13% to 15%; Increase the corporate income tax rate
See MoreTaiwan: Simplifies the conditions for the application of advance pricing agreement
The Ministry of Finance has simplified the conditions for the application of an advance pricing agreement (APA) and other procedural rules based on the amendments enacted on 6 March 2015. Accordingly, a taxpayer may apply for an APA if the total
See MoreColombian Tax Court rules on statute of limitations for penalties
In a recent court decision the Tax Court ruled on determining the statute of limitations for the tax authority to impose penalties. Article 638 of the Tax Code presents the statute of limitations for imposing penalties as a result of tax filing
See MoreEuropean Commission publishes Anti Tax Avoidance Package
The European Commission published its Anti Tax Avoidance Package on 28 January 2016. This package consists of the following main elements: Anti Tax Avoidance Directive The provisions of a proposed Anti Tax Avoidance Directive have been published
See MoreNigeria: Country-by-country reporting update
A Multilateral Competent Authority Agreement (MCAA) has been signed by Nigeria for executing the exchange of country-by-country (CbC) reports. This reports will include summary of income earned and tax paid, and the number of employees positioned by
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