Transfer Pricing Brief: August 2012
Belgium There are no specific provisions in relation to financial services, but fees must conform to the arm's length principle. Thin capitalization rules apply to restrict the tax deduction for interest on loans between related companies or loans
See MoreFrench Senators Axe Tax Break for Overtime Hours
It has been published on 30 July 2012 that, within the framework of its examination of the country’s second 2012 supplementary finance bill, the French Senate has abolished the tax exemption applicable to overtime hours in France, a measure
See MoreSingapore: Strengthen DTA Network
In a speech on 25 July 2012, at the international tax forum organized by the Tax Academy and CPA Australia, Singapore's Minister of State for Finance and Transport disclosed that Singapore was looking to strengthen its network of double taxation
See MoreChina and Hong Kong Special Administrative Region (SAR) update
According to an announcement made in October 2011, a Value-Added Tax (VAT) pilot program will be introduced in Shanghai in January 2012, replacing the business tax in selected industrial sectors. Following the early success of that pilot, it looks
See MoreSouth Africa: Introduces Tax Amendment Bills
It was published on 11 July 2012 that the South African National Treasury has released, for public comment prior to their formal introduction in parliament, the draft 2012 Taxation Laws Amendment Bills which give effect to most of the 2012
See MoreThailand Refuses To Give Foreign Dividend Tax Exemption
It was published on 9 July 2012 that the Deputy Prime Minister and Finance Minister have immediately rejected a call from Thailand’s business sector for a tax exemption on dividends received from overseas investments. The Thai Chamber of Commerce
See MoreCanada: welcomes IRS tax return help
Canadian Finance Minister has welcomed the US government's decision to help dual citizens residing in Canada deal with their US tax filing obligations. The Internal Revenue Service (IRS) will also offer assistance to those with Canadian retirement
See MoreAustria’s financial police enforce tax compliance
Austria’s Finance Minister Maria Fekter has recently underlined the key role of the country’s financial police in enforcing payment of due taxes and thereby ensuring tax justice in Austria. Alluding to the fact that the financial police now play
See MoreJapan’s Government and Opposition Agree Tax Deal
It was reported on 19 June 2012 that the Japanese Prime Minister has been successful in reaching a deal with opposition parties, and, in particular, the Liberal Democratic Party (LDP), on his plan for future hikes to the country’s consumption tax
See MoreItaly introduces tax measures for growth
The Italian government has issued its long-awaited decree aimed at boosting growth in the economy, particularly through tax incentives for construction companies, infrastructure projects and energy efficiency. Corrado Passera, the Economic
See MoreFinland: Deductibility of interest limitations
On 13 June 2012 it was published that the Finnish Government has released a draft regarding a bill to limit the deductibility of interest expenses in business taxation. The goal of this proposed regulation is to secure Finland’s tax base and to
See MoreHong Kong: No Tax Cut for SMEs
It was reported on 31 May 2012, that the government will not introduce a lower profits tax rate for micro-enterprises. There were about 300,000 small and medium-sized enterprises (SMEs) in Hong Kong by the end of 2011, accounting for more than 98%
See MoreUK: Tax Calculator App Launched
On 30 May 2012 it was reported that a new mobile phone application launched by HM Revenue and Customs (HMRC) will allow UK taxpayers to calculate how much tax they pay and how the government spends it. The app hints at the type of information which
See MoreSlovakia Unveils Special Bank Tax Plans
Slovakia’s Prime Minister has recently announced plans to introduce a special windfall tax on banks and to extend the existing tax on banking deposits, as part of government efforts to reduce the budget deficit. The Government plans to introduce a
See MoreSpain- New procedures on CIT and non-residents tax returns (regarding PEs)
By Order HAP/1023/2012 of 11 May 2012, the Ministry of Finance and Public Administrations of Spain approved the new forms, procedures and the stipulated periods for the corporate income tax (CIT) and the non-residents income tax returns (regarding
See MoreIndia- introduction of an APA program
The Finance Minister of India introduced the Finance Bill, 2012, on 16 March 2012 in which with respect to transfer pricing, the introduction of an advance pricing agreement (APA) program as well as other transfer pricing-related items has been
See MoreHong Kong launches APA programme
On March 29, 2012, the Inland Revenue Department (“IRD”) took an important step forward by formalizing the Advance Pricing Arrangement (“APA”) programme in Hong Kong. The IRD issued Departmental Interpretation and Practice Notes Number 48
See MoreFrance Publishes Revised 2012 ‘Black List’
It was reported on 26 April 2012 that the French Finance Minister and Budget Minister have recently updated the country’s ‘black list’ of countries deemed to be ‘uncooperative’ in tax matters. The revised 2012 list is confirmed in a
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