South Africa: proposal to limit interest deductions involving cross-border related party debt
The South African National Treasury released proposed legislation, on 4 July 2013, that seeks to limit interest deductions relating to debt owed by South African subsidiaries to foreign parent companies. The purpose of the proposed legislation is to
See MoreSouth Africa Consults On Budget Tax Reform Bill
On 4 July 2013 the National Treasury published the 2013 draft Taxation Laws Amendment Bill (TLAB) and the Tax Administration Laws Amendment Bill for public comment. The draft legislation would give effect to most of the tax proposals announced in
See MoreChina: Draft revisions to the tax collection and administration law
China’s Tax Collection and Administration (Law) which is the basic procedural law governs China’s tax administrative matters. It became effective from 1 January 1993. The Legislative Affairs Office of the State Council announced the
See MoreUN: Economic and Social Council to consider Manual on Transfer Pricing
A substantive session of the Economic and Social Council of the United Nations is taking place in Geneva from 1 to 26 July 2013. A draft resolution tabled for the meeting the Economic and Social Council notes the work of the Committee of Experts on
See MoreHong Kong: Tax reduction bill
The Inland Revenue (Amendment) (No. 2) Bill 2013 was passed on 26 June 2013 by the Hong Kong Legislative Assembly to implement the tax reduction measures proposed in the 2013-14 Budget. The concessionary revenue measures highlight the following
See MoreSlovenia: Modified Corporate Income Tax Law proposed
The Ministry of Finance on 20 May 2013 published a draft law on modifications to the taxation of companies. The proposal does not implement the previous plan of a further reduction in tax rates to 15 percent and instead proposes that the 17 percent
See MoreSouth Africa: tax penalty regime reformed
The National Treasury published the 2013 draft Taxation Laws Amendment Bill (TLAB) and the Tax Administration Laws Amendment Bill on 4 July 2013 for public comment. The draft legislation would give effect to most of the tax proposals announced in
See MoreHungary: Draft bill on the proposed changes to transfer pricing reporting obligations
The Ministry of National Economy of Hungary had announced a draft bill in March 2013. The draft bill proposed significant changes to the reporting requirements regarding the determination of arm’s length prices. According to the proposed changes
See MoreAustralia: Draft taxation determination on non-deductibility of support payments
The Australian Taxation Office (ATO) has discharged a draft Taxation Determination TD 2013/D3. The draft determination is appropriate to arrangements between a parent entity and its subsidiary entity. According to the draft TD 2013/D3, support
See MoreAustralia: Proposal to amend GAAR
The Australian government on 13th February 2013 introduced Tax Laws Amendment Bill 2013. According to Tax Laws Amendment Bill 2013, companies will have to ensure that the commercial and other factors motivating a decision are properly documented.
See MoreUkraine: Draft Law amendments regarding the formation of a tax group
Draft Law No. 2737 introduces amendments regarding the formation of a tax group. On 5 April 2013, amendments to the Tax Code were sent to be approved by the parliament. The legislation will allow companies in Ukraine to form a consolidated tax group
See MoreChile: Issuance of Resolution No. 14 of 2013
Resolution No. 14 of 2013 has been issued by the Chilean Internal Revenue Service (Chilean IRS) that contains the new Transfer Pricing Annual Informative Return for calendar year 2012 and the proper completing instructions. The deadline for filing
See MoreJapan: For 2013 tax reform proposals
The Tax Commission of Japan has submitted 2013 tax reform proposal on January 29, 2013 upon approval by the Cabinet. The suggested reform will be submitted to the Diet during February 2013 for consideration. The proposed main changes are summarized
See MoreRussia: Amendments to Tax Code regarding corporate property tax
Russian Federal Law No. 202-FZ, issued on November 29, 2012, amended the Tax Code by introducing additional exemptions from corporate property tax. From January 1, 2013, the categories of assets not subject to corporate property tax include movable
See MorePhilippines: Transfer Pricing Regulations
On 23 January 2013, the Philippines Secretary of Finance issued transfer pricing regulations (Revenue Regulation (RR) No. 02-2013). The regulations provide guidance for applying the arm’s length principle for pricing in related-party transactions
See MoreNew Swiss tax assistance law in effect
The Swiss Federal Council has announced that the new Tax Administrative Assistance Act (TAAA) will come into force on 1 February 2013. When the TAAA comes into effect the existing ordinance covering double taxation agreements will be repealed. The
See MoreVietnam: to cut CIT rate in 2014
The Ministry of Finance of Vietnam allotted a draft revision to the Law on Corporate Income Taxation on 12 December 2012. The proposed draft revision emphasized on the corporate income tax rates which will decrease from 25% to 23 % in 2014 also the
See MoreAmendments to Azerbaijani Tax Code
The Azerbaijani parliament adopted a draft law on amendments to the Tax Code on 21 December 2012, these came into effect from 1 January 2013. These changes are aimed at improving the tax system, reducing the tax burden and improving the tax culture.
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