Sweden: tax proposals in 2013 spring budget
The government of Sweden submitted to Parliament a budget bill on 15 April 2013 that proposes domestic tax changes. The measures include improving incentives to work, strengthening the income tax credit further and increasing the lower threshold for
See MoreSingapore: tax filing rate for 2013 has hit a record of 95%
The Inland Revenue Authority of Singapore (IRAS) has reported that by April 18, the individual tax filing rate in Singapore had reached a record high of 95% in this year compared to 94% last year. IRAS also added that more taxpayers will benefit
See MoreBelgium: New tax measures for 2013
Belgium’s Council of Ministers recently reached agreement on new tax measures for 2013. The Belgian government has already confirmed plans to increase the minimum wage and to reduce employer contributions from April 1. These measures are intended
See MoreNorway: Interest deduction limitation proposed
On 11 April 2013 the Norwegian Ministry of Finance published a legislative proposal and invited public submissions on the introduction of an interest deduction limitation for loans between related persons. The proposed limitation applies where there
See MoreHungary: Proposed Changes to Transfer Pricing Rules
The Ministry of National Economy (’the Ministry’) of Hungary has proposed changes to Hungarian transfer pricing documentation requirements. They have introduced provisions relating to low value added services and specified criteria for selection
See MoreUS: Public comments requested on branch profits tax for foreign corporations
The US Treasury Department and the Internal Revenue Service (IRS) are requesting comments concerning regulations TD 8223 (Branch Tax), TD 8432 (Branch Profits Tax) and TD 8657 (Regulations on Effectively Connected Income and the Branch Profits
See MoreUK challenges financial transactions tax
The UK has launched a legal challenge in the European Court of Justice to the planned financial transactions tax. This tax is to be introduced by eleven European countries under the EU provisions for enhanced cooperation and is planned to go into
See MoreMexico: Mining royalty plan
A proposal to levy a new royalty tax on mining profits in Mexico, the world’s largest producer of silver, passed a congressional committee on 16 April 2013. The proposal would also increase penalties for mining concessions that have not been
See MoreUK: HMRC issues revised GAAR guidance
HMRC’s latest guidance on the application of the General Anti-Abuse Rule (GAAR) was approved by the GAAR Advisory Panel on 15 April 2013. This guidance summarizes what the GAAR is intended to achieve and how it operates to arrive at this
See MoreSouth Africa: Tax measures included in 2013 budget
Certain tax proposals presented on 27 February 2013 in South Africa’s annual budget are summarized below: There were no tax increases but there was a substantial increase in fuel levies of 23 cents from April 2013. There was no specific mention of
See MoreJapan: 2013 tax reform bill has been passed
Japan’s 2013 tax reform bill passed on 29 March 2013 and the key changes are related to corporate taxation. They include the introduction of a tax credit for increased salaries paid to employees; the introduction of a tax credit / special
See MoreIndia: Tax Court rules on selection of comparables
In determining transfer prices between a taxpayer and related parties one of the permitted methods is the transactional net margin method (TNMM). This compares profit margins to an appropriate base such as sales, assets or costs realized from a
See MoreEU: Advocate General decides in favour of HMRC
The Advocate General has issued an opinion in a case referred to the European Court of Justice (ECJ) by the Danish High Court. The point at issue is whether the scope of Article 1(1) Regulation (EC) No 44/2001 includes an action brought by a State
See MoreArgentina –Modifications to the transfer pricing regulations through General Resolution N° 3,476
The Argentine Federal Tax Authorities issued General Resolution N° 3,476 on 10 April 2013. The Resolution has revised the transfer pricing compliance rules and introduced modifications to the current Transfer Pricing regulations. General Resolution
See MoreTransfer Pricing Brief: March 2013
Australia OECD Guidelines, the new transfer pricing rules require the provisions of the legislation to be interpreted so as to achieve the most consistency with the OECD Guidelines. Taxation Laws Amendment (Countering Tax Avoidance and
See MoreUS: Report on advance pricing agreements
The US report on advance pricing agreements issued on 25 March 2013 covers the activities of the program in 2012. At the beginning of 2012 the APA program was merged with the office of the competent authority (USCA) that is responsible for the
See MoreItaly: Report on international standard rulings
The tax authorities in Italy have issued a second International Standard Ruling Report. This provides statistics on the tax ruling system. Any enterprise that has international activities may apply for the process known as an international tax
See MoreGreece: Extension of Deadline for submission of certain tax returns
The deadline for submission of the tax returns for taxpayers falling into the scope of article 4 of paragraph 2 of the Income Tax Code has been extended until 31 May 2013, by the Ministry of Finance and all the tax returns are to be submitted solely
See More