US and Hong Kong- tax information exchange agreement (TIEA)
On April 25 2014 Hong Kong gazetted the tax information exchange agreement (TIEA) with the United States. The agreement will take effect after the relevant legislative procedures have been completed. The OECD has been encouraging the conclusion of
See MoreFrance: Unveils Medium Term Tax Strategy
France’s medium-term economic plan, included in the 2014-2017 Stability Program, involves measures that will help France to reach its public deficit target of 3 percent of gross domestic product (GDP) in 2015. Among the tax measures in the plan is
See MoreSingapore – GST rules affecting funds management industry
The Inland Revenue Authority of Singapore (IRAS) and the Monetary Authority of Singapore have finalized a set of rules relating to the impact of the goods and services tax (GST) on the funds management industry. Rules are laid down to establish the
See MoreSingapore – Finding of tax avoidance arrangement upheld on appeal
In Singapore a decision of the High Court on a tax avoidance arrangement has been upheld by the Court of Appeal. Although the taxpayer had made an arrangement to avoid tax the Court found that the Comptroller had acted beyond the powers bestowed by
See MoreMexico – Transfer pricing implications of pro-rata expense decision
A recent decision from Mexico’s Supreme Court of Justice declared a provision of the tax law to be unconstitutional. The provision related to pro-rata expenses incurred abroad relating to natural or legal persons that are not Mexican taxpayers.
See MoreLuxembourg: Adopts 2014 Budget
Luxembourg’s 2014 Budget has been adopted by the Chamber of Deputies. The debate in parliament was concerned with the Luxembourg Government’s intention to raise taxes with effect from 2015. The government also intends to increase three of the
See MoreRomania: Announces tax reforms
Romania is introducing a tax exemption on reinvested profit as part of an emergency ordinance. The tax exemption is to apply from 1 July 2014 and is to continue until the end of 2015. This is intended to encourage more investment in new assets in an
See MoreOECD: Issues Latest Tax Transparency Ratings
Twelve new reports have been issued by the OECD’s Global Forum, emphasizing measures that need to be taken by jurisdictions to reach the required international standard for the exchange of tax information. The “Global Forum on transparency and
See MoreMexico: Appeal procedures for certain challenges to tax reform
Mexico’s Supreme Court of Justice (Suprema Corte de Justicia de la Nación) has postponed the hearing of appeals in amparo actions, these being legal actions that challenge the constitutionality of some measures included in the 2014 tax reform.
See MoreColombia: issues regulations on thin capitalization provisions
The Colombian government issued Decree 627 on 26 March 2014. This Decree regulates the thin capitalization rules (article 118-1 of the Tax Code) that were brought in as part of the recent tax reforms and takes effect from the date of publication.
See MoreItaly: Government reduces IRAP rate and enacts other tax measures
Law Decree no. 66 published in the Official Gazette on 24 April 2014 confirms certain tax changes that were previously announced on 12 March 2014. The measures include a reduction of the regional tax on productive activities (IRAP) from a standard
See MoreHong Kong: Raises air passenger security charge
Hong Kong’s Airport Authority has raised the passenger security charge with effect from June 1 2014. This charge is paid by each passenger departing from Hong Kong International Airport and is to be increased by 36 percent. This passenger security
See MoreVietnam – Tax Revenue Receipts Increase
In Vietnam the tax collections in the first three months of 2014 reached VND134 trillion (USD6.37bn). This amount is 16.5 percent more than in the same period in 2013, and represents the highest level of first-quarter revenue in the past three
See MoreUS : Persons holding PFIC stock through tax-exempt organizations or accounts will be exempt from Form 8621 filing requirements
In the US the definition of a shareholder for the purpose of the Section 1291 regulations has been amended by Notice 2014-28. Under this section a special tax and interest charge is levied on a US person has shares in a passive foreign investment
See MoreUS: ATR finds that Obama has proposed 442 tax hikes
The organization known as Americans for Tax Reform (ATR) has calculated that since 2009 President Obama has proposed 442 tax increases. This figure results from a survey of the budgets for the fiscal years 2010 to 2015. In addition to these tax
See MoreUS – More taxpayers e-filing from home computers
An internal report issued by the Treasury Inspector General for Tax Administration (TIGTA) indicates that more US taxpayers are using e-filing to submit their tax returns and that more tax refunds are being issued. By 7 March 2014 more than 90
See MoreUS – IRS issues 2014 foreign housing tax deduction limits
In the US the Internal Revenue Service (IRS) has issued Notice 2014-29. The Notice sets out the inflation-adjusted limitations in respect of foreign housing expenses for tax year 2014. The figures included in the Notice show that Hong Kong, Moscow,
See MoreUS: GAO Reports that Large Partnerships are Avoiding the IRS Net
In a preliminary report from the United States Government Accountability Office (GAO) it is shown that the IRS is currently conducting a tax audit in respect of only around one percent of the largest partnerships in the US. The GAO report suggests
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