ECJ: Decision on state aid and Finland’s tax loss carry forward rules
A case was brought before the European Court of Justice (ECJ) concerning the question of whether Finland’s rules for carrying forward tax losses were contrary to the state aid provisions in Article 107 of the Treaty on the Functioning of the
See MoreEU: ECJ Rules on Denmark’s exit tax rules
The European Court of Justice (ECJ) on 18 July 2013 issued a decision in a case concerning Denmark’s exit tax. The case was brought by the European Commission. At the point where a person leaves Denmark an exit tax is calculated on the person’s
See MoreChile: Circular notifying transfer pricing changes
The Chilean Internal Revenue Service (IRS) has released Circular No. 29 on June 14, 2013 that includes instructions regarding the new transfer pricing rules introduced by Law 20,630. The circular recognizes the OECD TP Guidelines as a valid source
See MoreAustralia: Public disclosure of taxable income & tax payments
According to the provisions of legislation enacted in late June 2013, the Australian tax authorities will have to disclose publicly certain information relating to companies with a “reported total income” of greater than AUS $100 million. The
See MoreArgentina: New investment regime for the oil and gas industry
The Executive power of Argentina issued Decree N° 929/2013 to encourage investments in the oil and gas regime through new system. The Decree was published in the Official Gazette on July 15, 2013. According to the Decree eligible entities of the
See MoreWTO: Global Review of Aid for Trade
The fourth global review of Aid for Trade was held between 8 and 10 July 2013. The closing remarks by the Director General reminded the participants that the main targets of the program are to bring down trading costs while adding value to the trade
See MoreVietnam: Preferential customs treatment made more accessible
Under business policy in force in Vietnam since 2011 companies have had access to preferential customs treatment only if they have annual revenue of at least USD 350 million. A new Circular issued by the Ministry of Finance has lowered this
See MoreUkraine: penalty for failure to submit a controlled transaction report
From 1st September 2013, under the new transfer pricing law introduced in Ukraine, certain transactions between related and unrelated parties will be subject to the arm’s length principle and will be treated as controlled transactions under the
See MoreUK: VAT changes for telecommunications, broadcasting and e-services
The UK tax authority HMRC has issued a briefing on changes to the VAT place of supply rules affecting telecommunications, broadcasting and e-services from 1 January 2015. From that date where these services are supplied from a business established
See MoreHalf-Year Tax Revenues Fall in Taiwan
Taiwan's Ministry of Finance has announced a 5.2 percent fall in revenue in June 2013 due to a fall in receipts from corporate taxes. There has been a decrease in total tax collections in the first half of this year which includes falls in
See MoreSouth Africa: proposal to limit interest deductions involving cross-border related party debt
The South African National Treasury released proposed legislation, on 4 July 2013, that seeks to limit interest deductions relating to debt owed by South African subsidiaries to foreign parent companies. The purpose of the proposed legislation is to
See MoreSouth Africa: E-Filing for Excise Duties
South Africa published Government Notice R.487 on 11 July 2013 providing for all excise accounts to be submitted on e-Filing with immediate effect. Manual submissions will only be accepted for a period of three months from 11 July 2013. After the
See MoreSouth Africa Consults On Budget Tax Reform Bill
On 4 July 2013 the National Treasury published the 2013 draft Taxation Laws Amendment Bill (TLAB) and the Tax Administration Laws Amendment Bill for public comment. The draft legislation would give effect to most of the tax proposals announced in
See MorePortugal: Madeira’s International Business Center regime transfer pricing deadline
Among other tax incentives, the new Madeira International Business Centre (MIBC) regime introduced by Portugal provides reduced corporate income tax rates of 4% (in 2012) and 5% between 2013 and 2020. Under the new regime companies are required to
See MorePeru: Changes to transfer pricing documentation requirements
The Resolution 175-2013 of Peru sets out regulations concerning new transfer pricing documentation requirements which have become effective from 1 June 2013. According to the new rule taxpayers subject to the transfer pricing rules are required to
See MoreNetherlands: Additional Bill on taxation of rental income passed
The additional Bill on the taxation of rental income for 2013 was published in the Official Gazette on 12 July 2013. Rental income from housing in the regulated sector will become liable to a special levy based on the value of the house. In 2013,
See MoreMalaysia: Deduction for Acquisition of Foreign Owned Company Rules
The Income Tax (Deduction for Cost of Acquisition of Foreign Owned Company) Rules 2013 were published in the official gazette on 4 July 2013. The rules are however deemed to have come into operation on 3 July 2012. The Rules provide that for the
See MoreItaly: Approval of new nonresident forms for mitigation of withholding taxes
The Italian tax authorities released revised and updated versions of forms on 11 July 2013 which is to be used by non-residents in filing claims for an exemption, refund or reduction of Italian taxes on dividends, interest, royalties and other
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