France updates list of tax havens
France has revised its list of tax havens to include Jersey, Bermuda and the British Virgin Islands as tax havens, meaning the three territories will be subject to tougher tax policies applied by France. France has however removed the Philippines
See MoreGermany: Draft regulation for the profit attribution to PEs issued for public discussion
The draft version of a new Regulation on the attribution of profits to permanent establishments (PE Regulation) has been issued on 5 August 2013 by the German Ministry of Finance for public discussion. The main goal of the PE Regulation is to
See MoreIndia – Indian government set up its first Tax Administration Reform Commission
The Indian government set up its first Tax Administration Reform Commission on 26 August 2013. The seven-member panel is being given eighteen months to draw up its recommendations. The Commission is likely to put forward proposals for the creation
See MoreLithuania: Real estate tax exemption relating to agricultural activities
The tax law of Lithuania has been modified to arrange for an exemption from real estate tax for an entity’s real property when the entity is involved in agricultural activities. The amendment will become effective from January 2014. An exemption
See MoreMalaysia: Hike in Property Gains Tax
Malaysia is considering a hike in the real property gains tax (RPGT), which is imposed on the profits from the sale of properties within certain periods after their purchase. This would be done to restrict what is seen as too much speculation in the
See MoreMexican Tax Authority increases focus on auditing supply chain structures
Recent developments within the Mexican Tax Administration Services (SAT) demonstrate an increased focus on auditing supply chain restructurings. This is in line with international trends in transfer pricing, for example the report on business
See MoreNigeria: Installment payments against lump-sum tax payment
Nigeria’s tax authority has published in a local newspaper a request to taxpayers to submit their tax return for 2013 on August 12, 2013 and it focused on the rules for companies to file returns and fix obligations of their income tax, and the
See MorePortugal: Extraordinary investment tax credit to boost investment is introduced
The Portuguese government introduced an extraordinary investment tax credit with effect from 17 July 2013. The special tax credit will be applicable to investments between 1 July 2013 and 31 December 2013, up to a limit of EUR 5,000,000. The tax
See MoreSouth Africa: Tax consequences of debt reduction transactions
South Africa’s Taxation Laws Amendment Act, 2012, includes provisions that revise the tax treatment of debt reduction transactions entered into on or after 1 January 2013. Since the objective of the new tax reduction rules is to make it easier
See MoreSouth Korea- Planning of Acquisition Tax Cuts
The South Korean Government announced on 30 August 2013 that the tax rates on home purchases would be decreased in order to encourage a rise in transaction numbers. An exemption from property acquisition tax was granted in April 2013, but the
See MoreSwitzerland agrees plans for settling US Tax conflict
The Federal Council of Switzerland has agreed to plans for reconciling the Confederation’s tax conflict with the US. The Council of the Federal Finance Department has established a mutual statement designed to draw a line under past dispute over
See MoreUK introduces employee shareholder status
From 1 September 2013 employee shareholder status has been introduced in the UK. This allows an employer to enter into a contract with an employee whereby some employment rights are given up by the employee in exchange for shares in the employer’s
See MoreUK: alternative dispute resolution is now available to SMEs and individuals
From 2 September 2013 alternative dispute resolution (ADR) is now available to small and medium enterprises (SMEs) and individuals. If a taxpayer that is in dispute with HMRC asks for ADR a facilitator will be appointed from within HMRC. The
See MoreUK: Corporation tax statistics
On 30 August 2013 HMRC released the latest corporation tax statistics. The publication shows the statistics for corporation tax receipts for 2012/13 and some revised figures in relation to corporation tax liabilities of previous years. Also shown
See MoreTransfer Pricing Brief: August 2013
Indonesia Certain small and medium enterprises may be taxed on the basis of 1% of turnover. Israel Lower rates apply to companies eligible under the Law for the Encouragement of Capital Investment. Malaysia A Transfer Pricing Audit Framework
See MoreAustralia: Effective date of new Transfer Pricing rules
The new transfer pricing rules introduced by Australia are effective for years starting on or after 1st July 2013 and will apply to the transactions of all multinational entities operating in Australia. Before documenting their assessment forms,
See MoreBelgium: Introduction of “fairness tax” on companies
The Belgian government has introduced a “fairness tax” on companies. Due to compensation for losses or notional interest deductions, if companies dividends are paid and corporate tax is not paid, will be liable to pay this fairness tax. In an
See MoreBrazil: 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
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