Chile: Guidance on statement needed to benefit from a tax treaty
The Internal Revenue Service has issued Resolution No. 48 along with instructions on 25th May 2015 regarding the contents of a confirmed statement to be requested by a Chilean payer from a beneficiary resident in a tax treaty country due to apply
See MoreCanada: Draft legislation released implementing events from Economic Action Plan 2015
The Finance Minister has published draft legislative proposals on 31st July 2015 that would implement certain tax measures from the Economic Action Plan 2015 including: Amending the frequent failure report of income penalty to apply only for a
See MoreWorld Tax Brief: June to July 2015
Austria Withholding tax on dividend distributions, capital gains: The withholding tax rate for dividends and capital gains will be increased to 27.5% (up from the current rate of 25%). If dividends are paid to corporations, a reduced withholding
See MoreCanadian parties announce election campaigns
The Prime Minister of Canada has declared election campaign for his party with a statement that the Internship Job Creation Tax Credit will be improved. The federal general election will go on 19th October
See MoreTransfer Pricing Brief: July 2015
India: Comparable data range: The Punjab and Haryana High Court confirmed a judgment in the case of CIT-I v. DSM Anti Infectives India Ltd. ITA No. 116 of 2014 of a tax appellate tribunal that certain companies could be appropriate
See MoreECJ: 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
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