Brazil: Guidance Issued on the Pricing of Interest Bearing Transactions
The Brazilian Ministry of Finance has issued an ordinance 427/2013, On 2 August 2013, which finally define and clarifies the interest rate spread and that was mentioned but not specified in Law 12.766/2012. Under Ordinance 427/2013 where the
See MoreCanada – Amends to foreign affiliate dumping rules proposed by the Government
The draft legislation has introduced on August 16, 2013, to make revisions to the foreign affiliate dumping (FAD) rules that were first declared as part of the 2012 federal budget and enacted on December 14, 2012 according to Bill C-45 and it would
See MoreChina: Eligibility of software enterprises for corporate income tax incentives
To clarify the rules concerning software enterprises that are eligible for certain corporate income tax incentives, China’s State Administration of Taxation has issued guidance on the issues arising in qualifying for these incentives. According
See MoreColombia: Agreement with World Bank on Tax Matters
The World Bank signed an agreement with Colombia on August 19, 2013. This is to improve its tax collection. The agreement will be in force between August 2013 and August 2015. In order to strengthening the tax system, the World Bank will supply
See MoreCroatia: Government proposes amendments to Individual Income Tax Law
The government has proposed amendments to the Individual Income Tax Law on 25 July 2013. Following the constitutional court decision these amendments provide that dividends or participation in profits obtained after 31 December 2000, but paid out
See MoreCyprus: Tax treatment of loan write-off by a financial institution
Recently guidance with respect to the tax treatment of a loan write-off by a financial institution, for the benefit of the borrower, has been issued by the tax authority of Cyprus. According to Circular 2013/14 of 30th May 2013, a partial or
See MoreDenmark :Corporate income tax rate will be reduce to 22% by 2016
The Danish Parliament has recently passed two bills which are part of the government’s economic growth plan. The current corporate tax rate is 25% but this will be reduced to 22% by 2016 under the growth plan. The phased-in reduction of the
See MoreECJ: Advocate General issues an opinion on the VAT exemption for educational services
Details of the opinion of the Advocate General of the European Court of Justice (ECJ) in respect of questions on VAT and education services are now available. The opinion was given in relation questions referred to the ECJ in relation to a case
See MoreFrance introduces bill on new tax incentives for entrepreneurs
The government of France introduced a Bill into the National Assembly on 21 August 2013 in relation to tax incentives for entrepreneurs in crafts, trade and small businesses. Accordingly, entrepreneurs are exempt from the additional tax on real
See MoreFrance: New deductions enacted on capital gains
The government of France issued a circular on 9 August 2013 on reductions of capital gains for individual income tax and social contributions purposes. Capital gains derived from the disposal of immovable property other than land benefit from the
See MoreIndia – CBDT Releases Drafts on Transfer Pricing Safe Harbor Rules
India’s Central Board of Direct Taxes (CBDT) released draft transfer pricing “safe harbor” rules as part of an initiative by the government to reduce the number of transfer pricing audits and protracted disputes on 14th August 2013,. Under the
See MoreIndia – No transfer pricing adjustment required on certain interest-free advances
Recently, Income Tax Appellate Tribunal by a ruling rejected and deleted transfer pricing adjustments proposed with respect to a taxpayer’s interest-free advances made to its related party (a U.S. subsidiary) on a finding that the taxpayer had
See MoreItaly: Decree on Final Exit Tax has been published
The Ministerial Decree of 2 August 2013 is implementing new rules on 12th August 2013 regarding the income tax treatment of the migration of Italian companies which was published in the Italian Official Gazette n. 188/2013. According to the Decree,
See MoreLuxembourg publishes Circular on Minimum Corporate Income Tax (MCIT)
The Luxembourg tax authority published a circular L.I.R. no. 174/1 on 1 August 2013. This relates to the Minimum Corporate Income Tax (MCIT). The most significant parts of the circular are given below: Luxembourg permanent establishments are not
See MoreNew Zealand reforms the Inland Revenue Department
The New Zealand Government has announced to reform the Inland Revenue Department which intended to make it easier and less costly to taxpayers’. The first things of changes need to improvements of processes, skills and capabilities, and
See MorePhilippine: Collect taxes from online sellers
The Bureau of Internal Revenue (BIR) of Philippines’ has released a memorandum, which is ensure that it will start accumulate taxes from individuals and businesses for selling products online. This measure is already permitted under the tax law
See MoreRomania: Reduced VAT for bakery products
A change in the VAT rate in respect of bakery products is contained in Government Ordinance no. 16/2013 which was published in the official journal (no. 490, 2 August 2013). The reduced value added tax (VAT) rate of 9% will apply to the supply of
See MoreRussia- Draft amendments to Tax Code
The government of Russia has introduced Draft Law No. 330414-6 to parliament on August 10, 2013 that amends the Tax Code regarding the rules applicable to tax audits of banks and is expected to entry into force one month after its publication. Banks
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