US: Treasury Department and IRS Released Temporary Regulations and Proposed Regulations to Clarify the Arm’s Length Standard
The Treasury Department and IRS released for publication in the Federal Register Temporary regulations (T.D. 9738) on 15 September 2015 to clarify the arm’s length standard and the best method rule under Code section 482 and the regulations
See MoreOECD Issues Policy Framework for Investment
The 2015 edition of the OECD publication Policy Framework for Investment published on the OECD on its website on 14 September 2015 provides guidance on improving the environment for investment in a number of fields of policy. The publication
See MoreECJ: Advocate General issues an opinion involving dividend taxation and free movement of capital
The Advocate General of the European Court of Justice (ECJ) issued an opinion on 10 September 2015 in the case of Pensioenfonds Metaal en Techniek v Skatteverket (Case C-252/14). The Supreme Administrative Court of Sweden had asked the ECJ for a
See MoreItaly: Extended the Statute of Limitation to Double in Criminal Tax Investigations
Italy has published the decree in the Official Gazette on 18 August 2015 on new anti-¬abuse rule and other measures to enhance legal certainty in tax matters. It became effective on 2 September 2015. The decree also modifies the rules on the
See MoreMexico: Tax reform proposal submitted to congress
The Mexican tax reform proposal presented to congress on September 8, 2015 which includes supplementary transfer pricing documentation requirements in line with the three-tiered approaches of Action 13 of the OECD like master file and local file
See MoreRomania: New fiscal code published addressing corporate tax regime amendments
Romanian government published the Law no. 227/2015 regarding the Fiscal Code on 10 September, 2015. The new Fiscal Code, coming into force in 2016 which brings the following amendments for the corporate and micro-enterprise income taxation
See MoreCanada: Conservative party pledges payroll tax cut
The Prime Minister of Canada has declared that a re-elected conservative government would cut more than 20% payroll taxes in 2017. He promised that his government would not increase payroll taxes in the Canada Pension Plan (CPP) and also accused the
See MoreSaudi Arabia: IMF comments on economic and fiscal position
The IMF issued a report on 9 September 2015 following the conclusion of consultations with Saudi Arabia under Article IV of its articles of agreement. Saudi Arabia has been one of the strongest growing G20 economies, but with the recent fall in the
See MoreNorway: IMF comments on economic and fiscal issues
The IMF has recently concluded discussions with Norway under Article IV of its articles of agreement and has issued a staff report and selected issues paper on aspects of the Norwegian economy. The mainland (non-oil) GDP growth was 2.2% in 2014,
See MoreRomania enacts new Fiscal Procedure Code
The Romanian tax authority has published the revised Fiscal Procedure Code in the Official Gazette no. 545 dated 23 July 2015. The existing Fiscal Procedure Code is being updated by Law 207/2015 implementing new provisions with respect to tax
See MoreUK: Research into motivators and incentives for voluntary disclosure
HMRC has published a report on the findings of a research project on drivers for taxpayer participation in voluntary disclosure opportunities. The project involved 38 interviews with taxpayers who had either disclosed voluntarily; been investigated
See MorePeru: Proposal for CGT exemption for certain transfers of shares
The President presented to the Peruvian Congress on 24 August 2015 a bill proposing temporary tax exemptions from capital gains tax arising from the transfer of shares carried out through the Lima Stock Exchange. To obtain the exemption certain
See MoreUK: HMRC research into business cycles and tax reporting
On 8 September 2015 HMRC published on its website research on understanding the impact of reporting cycles. This examined the business experience and compliance behaviour of small and medium sized enterprises (SMEs) and asked for information on the
See MoreIMF: Fair Taxation in the Middle East and North Africa
The IMF published Staff Discussion Note 15/16 on 2 September 2015 dealing with the subject of fair taxation in the Middle East and North Africa (MENA). The notes look at how tax systems can contribute to meeting demands for greater fairness in the
See MoreOECD: Taxation of Small and Medium Enterprises
The OECD has issued a publication on the taxation of small and medium enterprises (SMEs) in OECD and G20 countries. The report examines tax policy and administration in relation to SMEs, noting that these firms generally represent more than 95% of
See MoreUK: HMRC Publishes Results of Large Business Panel Survey 2014
The results of the Large Business Panel Survey for 2014 have been published on HMRC’s website. The survey of large businesses was performed in late 2014 and early 2015. The aim was to track and assess the views of businesses on the services
See MoreIndia: No related-party relationship, despite substantial single-party purchases
In the case of: DCIT v. W.B. Engineers International Pvt. Ltd. (ITA No. 523/PN/2014, The Pune Bench of the Income-tax Appellate Tribunal upheld the findings of the Dispute Resolution Panel that because a taxpayer merely hold substantial
See MoreGermany: Ratification of Protocol to OECD Convention on Mutual Administrative Assistance in Tax Matters
Germany deposited its instrument of ratification on 28 August 2015 for the protocol to the OECD Multilateral Convention on Mutual Administrative Assistance in Tax Matters. It is anticipated that the agreement will enter into force on 1 December
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