China: Taxable presence of foreign entity’s seconded workers
Recently a guidance concerning when the cross-border secondment of expatriate workers by foreign enterprises into China may give rise to a taxable presence in China is issued by the China’s State Administration of Taxation. Factors taken into
See MoreBrazil: Expands Threshold for Companies for presumed Profit Method
The profit method is one of four calculation regimes that may be applied by some companies for the computation of profits for Brazil’s corporate income tax. This is a simplified regime that enables a company to pay tax based on a percentage of its
See MoreAustralia: Amends Transfer Pricing Regulations
Australia has introduced the Tax Laws Amendment (Countering Tax Avoidance and Multinational Profit Shifting) Bill 2013 (“the Bill”) in the House of Representatives for approval. The new transfer pricing regulations will significantly bolster the
See MoreUkraine: New transfer pricing law
A transfer pricing Bill to amend the legislation with regard to transfer pricing and introduce best practice was registered with parliament on 12 March 2013. The Tax and Customs Committee of parliament has confirmed that the Transfer Pricing Bill
See MoreGermany: Amendments to the taxation of portfolio dividends
A new law in respect of dividend taxation was published in the Federal Gazette on 21 March 2013. This law has been introduced following a decision of the European Court of Justice in 20 October 2011 which required a review of the taxation of
See MoreAustria:Corporate tax guidelines limit interest deductions
The Austrian Ministry of Finance published revised corporate income tax guidelines in March 2013, to tightening the rules with respect to interest deductions in connection with “debt push-down models” and concerning tax loss carry forwards
See MoreFrance-Modification to capital gains tax regime
The President of France announced on 29 April 2013 that the tax regime on capital gains is to be modified. To encourage entrepreneurship the government will simplify the different existing regimes. Since 1 January 2013, occasional capital gains on
See MoreColombia: Proposed Regulations for Bank Debit Tax
The Colombian Government is currently preparing a Decree, which will regulate the provisions of bank debit tax. This bank debit tax was introduced by Law 1607 of 2012. This proposed Decree will provide for exemptions and the refund of the bank debit
See MoreUK overseas territories agree to exchange tax information
A number of UK overseas territories and crown dependencies have agreed to exchange information on tax matters with the UK and other major European countries. Anguilla, Bermuda, the British Virgin Islands (BVI), Montserrat and the Turks and Caicos
See MoreRussia: VAT treatment of agency services in connection with alienation of ERUs
The Russian Ministry of Finance has noted that the VAT treatment of services generally depends on the place of their supply. Recently they issued Letter No. 03-07-08/4775 on February 20, 2013 regarding the VAT treatment of agency services supplied
See MoreTransfer Pricing Brief: April 2013
Argentina Resolución General N° 3476 introduced new Form F4501, for filing the transfer pricing documentation report. Finland Main corporate income tax rate has been reduced to 20%. India Circular 2/2013 clarifies that the profit split
See MoreUK: HMRC announces widespread compliance with real time information
Most UK employers are now required to report their information on wages and deductions under the Pay as you Earn (PAYE) scheme in real time. The UK tax authority HMRC announced last week that more than 680,000 employers have begun reporting PAYE in
See MoreSlovenia: Raises VAT Registration Threshold
Generally EU member states follow the compulsory VAT registration thresholds set in the EU VAT Directives. The EU permitted Slovenia to raise its compulsory VAT registration threshold from €25,000 to €50,000 per annum, so businesses with taxable
See MoreLuxembourg: Standard VAT rate will increase from 2015
The Luxembourg Prime Minister announced on 10 April 2013 that, the standard VAT rate will increase as from 2015, but the new rate has not yet been announced. The standard VAT rate is presently 15percent and is the lowest in the EU. The Luxembourg
See MoreChina: Permitted Industry Catalogue published for Qianhai Shenzhen-Hong Kong Modern Service Industry Cooperation Zone
For the Qianhai Shenzhen-Hong Kong Modern Service Industry Cooperation Zone, the Permitted Industry Catalogue was issued in March 2013. This sets out six permitted industries which include financial services, modern logistics, information services,
See MoreIndia: Central government has issued Notification on transfer pricing tolerance band
If the transfer price charged by a taxpayer is within a certain percentage of the arm’s length price determined under section 92C of India’s Income Tax Act no adjustment is required. In previous years there has been some misunderstanding as to
See MoreUK: report on the role of large accountancy firms in tax avoidance
The UK’s Parliamentary Accounts Committee (PAC) has issued a report entitled “Tax avoidance: the role of large accountancy firms” criticizing the close relationship between accountancy firms and the tax authorities. The practice of seconding
See MoreUnited Arab Emirates: Abu Dhabi issues a decree establishing a financial free zone
The free zone is expected to be set up along the same lines as the financial free zone in Dubai and will help Abu Dhabi to compete as a financial centre with Dubai and other jurisdictions in the region such as Qatar and Saudi Arabia. The free zone
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