Mexico: 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 MoreIreland: Finance Act 2013
The Irish Finance Bill 2013, which was published on 13 February 2013, was enacted on 27 March 2013 as the Finance Act 2013. Modifications have been made to the tax regime for start-up companies. These companies currently are not required to pay
See MoreColombia: Introduces Corporate Tax Reforms
The Colombian Government has introduced measures relating to corporate tax changes. For the purposes of corporate tax, it redefined the concept of permanent establishment. Corporate income tax rate for companies and for non-resident companies
See MoreAustralia: Publication of changes in Pension Taxation
The Australian government has published a plan for the tax exemption on pension earnings in superannuation accounts to be capped at $100,000, with any amounts above that threshold to be taxed at 15%. Currently a 15% tax applies to earnings from
See MoreKorea: Update on rules for application of arm’s length standard to head office–branch transactions
Korea’s Ministry of Strategy and Finance has issued new regulations to clarify the method for calculating domestic-source income from intra-company transactions between a foreign head office and its Korean branch. This follows the passing of the
See MoreFinland: Government’s 3-Year Tax Plan
The Finnish government has formed a new 3-year spending plan to respond to the current decline in the Finnish economy. The plan covers the years from 2014-2017. The main key points of the plan are as follows: • Corporate income tax will be
See MoreChina: Non-resident enterprises – tax collection in 2012
A report on statistics compiled by China’s State Administration of Taxation (SAT) indicates that the tax paid in 2012 by non-resident enterprises in China showed a slight increase, following a sharper rise in the previous year, and amounted to
See MoreIndia: Guidelines for application of the profit split method
India’s Central Board of Direct Taxes (CBDT) has issued Circular No. 2 of 2013, setting out guidelines for application of the Profit Split Method (PSM) in international transactions. The profit split method is one of the permitted methods for
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