Australia: New Taxation Ruling TR 2014/6 introduced by the Australian Taxation Office (ATO)
Taxation Ruling TR 2014/6 gives guidance on identifying situations where the form of commercial or financial relations differs from the substance and confirms the ATO's power to disregard and reconstruct transactions that lack economic substance.
See MoreSlovak Republic: Regulation regarding binding rulings has published
The Ministry of Finance published Regulation No. 229/2014 that gives the tax aspects for which binding rulings may be issued and this regulation came into effect from September 1, 2014. On the basis of the regulation, binding rulings can be issued
See MoreUS: Internal Revenue Service (IRS) loses appeal on the reforms of legislation for tax preparers
The United States Internal Revenue Service (IRS) has lost its appeal on the reforms of rules for tax preparers against the ruling by the court that ordered to stop enforcing regulatory requirements on tax return preparers. The ruling is important
See MoreBrazil – Tax authority revises position on cross-border reimbursement arrangements
Brazil’s tax authority has issued a ruling to a taxpayer reflecting a change of position concerning cross-border cost reimbursement arrangements. Traditionally, the tax authority (Receita Federal do Brazil—RFB) has imposed a high tax burden of
See MoreBrazil – Ruling permits taxpayers to align their transfer pricing policies
According to a recent ruling by the Brazilian tax authority taxpayers should be able to better align their transfer pricing policies to eliminate potential contingent liabilities, reduce taxable adjustments, and/or eliminate the double taxation
See MoreItaly: Changes in international ruling procedure
Italy has modified its international tax ruling procedure, through Art. 7 of Law Decree No. 145/2013. Under this, non-resident entities operating in Italy may obtain an advance ruling on whether their activities in Italy give rise to a PE under
See MoreHong Kong: Court of Final Appeal decision on unrealized revaluation gains
Hong Kong’s Court of Final Appeal (CFA) ruled that year-end unrealized revaluation gains on listed securities held for sale were not taxable in Hong Kong. In a case called Nice Cheer Investment Limited (NCIL), the CFA rejected the CIR’s
See MoreBrazil established new tax accounting rules
A provisional measure was published in Brazil on 15 November 2013, to establish new tax accounting rules which rescinds the transitional tax regime method and establishes the new tax rules to align Brazil’s tax accounting rules with the current
See MoreIsrael-Online Advance Tax Ruling Requests
The Tax Authority of Israel has recently announced that it has adopted a trick to improve services and reduce bureaucracy for tax advisers by launching a new service which will allow accountants, lawyers and tax practitioners to apply online for
See MoreSouth Africa: Private ruling on capital gains tax in South Africa
A ruling has been issued that may help taxpayers to determine the tax position in a situation where a loan has been cancelled. On 13 August 2013, the South African Revenue Service (SARS) issued a binding private ruling dealing with the question as
See MoreSARS Updates ATR Application Process
The process of application for a tax ruling is sometimes seen by taxpayers as daunting and they may prefer not to embark on the procedure even though it can provide them with some certainty as to the outcome of planned transactions. There is
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 MoreUS: IRS Announces Interest Rates on tax overpayments and underpayments for 2013 second quarter.
The US Internal Revenue Service has issued Revenue Ruling 2013-6 with the announcement of the interest rates on tax overpayments and tax underpayments for the calendar quarter beginning 1 April 2013. The rate will remain the same as in the previous
See MoreRuling on Taxes within DTAs Provided in South Africa
The Legal and Policy Division of the South African Revenue Service (SARS) has issued a Binding General Ruling (BGR) on income taxes, or substantially similar taxes, following the double tax agreements (DTAs) of South Africa. According to this BGR
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