Spain: BEPS country by country reporting provisions enacted
The Spanish Ministry of Finance published Royal Decree 634/2015 of 10 July 2015 in the Official Gazette on 11 July, 2015. The Decree contains corporate income tax regulations including (BEPS) country by country reporting requirements in line
See MoreGreece: tax authorities issue circular to clarify transfer pricing regulations
The Greek tax authorities issued circular no. POL 1142/02.07.2015 dated July 2, 2015 to explain transfer pricing (TP) documentation issues raised in light of the new Income Tax Law no. L. 4172/2013 and Tax Procedures Code no. L. 4174/2013. The
See MoreNew guidance on Advance Pricing Agreements issued by Australian Taxation Office
The Australian Taxation Office released its revised policies and procedures for the Advance Pricing Agreements program on 23 July 2015. The updated guidance has been provided in the form of Practice Statement Law Administration PSLA 2015/4, which
See MoreUK: Consultation on extension of HMRC data gathering powers
On 22 July 2015 the UK tax authority HMRC issued a consultation document entitled “Tackling the Hidden Economy: Extension of Data Gathering Powers”. HMRC estimated that in 2012/13 the element of the tax gap caused by the hidden economy amounted
See MoreCzech Republic: VAT reverse charge extended
The VAT reverse charge for a range of agricultural crops has been extended by the tax office. The local reverse charge mechanism is a tool used to help prevent so-called missing trader VAT fraud. This is a fraud whereby criminals target the EU
See MoreUK: Consultation on strengthening sanctions for tax avoidance
On 22 July 2015 the UK government issued a consultation document containing detailed proposals for strengthening the penalties for tax avoidance. The closing date for comments on this consultation document is 14 October 2015. Serial avoiders’
See MoreUK: Consultation on improving large business tax compliance
On 22 July 2015 the UK tax authority HMRC launched a consultation on improving large business tax compliance. In the 2015 budget the UK government stated its intention to open a consultation on the measures that could be taken to improve tax
See MoreGermany plans to adopt BEPS guidance on transfer pricing documentation and CbC reporting requirement
The German government has announced plans to incorporate guidance on transfer pricing documentation and country-by-country (CbC) reporting) in line with the OECD’s Base Erosion and Profit Shifting (BEPS) project into local legislation. The
See MoreIrish Revenue clarifies effect of ECJ decisions on VAT rules
On 17 July 2015 the Irish Revenue issued eBrief 73/15 outlining the practical implications of certain decisions of the European Court of Justice (ECJ) in value added tax (VAT) cases. The issues are related to VAT issues for pension funds. Supply of
See MoreCzech tax authorities clarify implications of ECJ Skandia decision
A clarification was recently issued by the Czech Republic tax administration in relation to the implications of the Skandia America decision of the European Court of Justice (ECJ). The ECJ decision concerned Skandia which was a US corporation with
See MoreFrance introduces withholding tax on benefits from employment
On 17 June 2015, the Ministries of Finances and Budget declared that a withholding tax system for fringe benefits will be introduced in France and will come into effect from 1 January 2018. It is expected that the withholding tax will be processed
See MoreHong Kong: Exemption for offshore funds
The Hong Kong government has Gazetted the Inland Revenue (Amendment) (No.2) Ordinance 2015, which seeks to extend the profits tax exemption for offshore funds to private equity funds. With the implementation of the Amendment Ordinance, transactions
See MoreCyprus: Parliament Enacts Tax Law Amendments
On 9 July 2015 the House of Representatives of Cyprus enacted into law a number of significant tax law proposals. The laws were published in the Cyprus Government Gazette on 16 July 2015. A number of changes to the Cyprus corporate and personal
See MoreSlovenia: Procedures for Advance Pricing Agreements
The Ministry of Finance has published proposed changes to the Slovenian Tax Procedure Act. The envisaged amendments bring a broad variety of important amendments regarding automatic exchange of information and elimination of administrative
See MoreUK: HMRC issues consultation document on intermediaries legislation
On 17 July 2015 HMRC issued a consultation document on the intermediaries legislation (IR35). The intermediaries legislation was first introduced in 2000 to combat tax avoidance through intermediaries such as personal service companies. The
See MoreWorld Bank and IMF announce further support for developing country tax administrations
The World Bank and the IMF announced on 10 July 2015 that they are launching an initiative to support developing countries in strengthening their tax administrations. Research has suggested that there is potential for lower income countries to
See MoreUK: HMRC launches consultations on penalties for offshore non-compliance
On 16 July 2015 the UK tax authority HMRC launched consultations on penalties for non-compliance in relation to offshore income and assets. The consultation papers consider options for strengthening civil penalties for tax evasion involving hiding
See MoreUK: HMRC publishes research report on use of offshore disclosure facilities
On 15 July 2015 HMRC published a research report on behavioral factors influencing the use of offshore disclosure facilities. The research was conducted by interviews with agents handling offshore disclosure cases; in this case those involved with
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