Slovenia: 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 MoreAustralia: Practice statement on Transfer Pricing
The Australian Customs and Border Protection Service (Customs) has published Practice Statement B_IND08 “Valuation-Transfer Pricing Policy” and this new practice statement will replace Practice Statement PS 2009/21 on the subject. The
See MoreArgentina: New process for determining “tax haven” jurisdictions
Argentina’s tax authority (AFIP) has issued a decree introducing new criteria for when to consider countries as “tax haven” jurisdictions for transfer pricing purposes. This Decree was published on May 30, 2013. The Decree states that the AFIP
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 MoreCzech Republic: Proposals on dividends, stock gains and increased R&D
The Czech Republic government has submitted its long-discussed proposals on April, 2013 to “re-codify” the tax laws to the Chamber of Deputies with a proposed effective date of January 1, 2014. The main proposals are summarized below: Dividends,
See MoreAustralia: Budget 2013
The Australian government released its budget for 2013 on May 2013. It includes plans for a number of revenue / tax expenditure changes including measures to combat profit shifting. According to the budget, business entities will be eligible for
See MoreLuxembourg’s Corporate Tax Plans made public
The Luxembourg Government has uncovered some details of its future corporate tax plans. Increasing the rate of business tax has been ruled out by the Government. They have however confirmed plans to further simplify and modernize tax procedures for
See MoreEgypt: New Tax Law
A new tax law was signed by the Egyptian president on 21 May 2013. The new tax law cuts the amount of tax paid by those on lower incomes and this is intended to improve their living conditions. According to the new law anyone who earns EGP 5,000 or
See MoreKorea: Foreign exchange profit taxable as dividend income
Korea’s high court has issued a judgment in a case where a taxpayer received an amount less than the principal investment on the sale of participations in Japanese funds, which was offset to some extent by foreign exchange gains from the strength
See MoreGermany: Taxation of portfolio dividends; gain, loss on mergers
A new law concerning the taxation of portfolio dividends has been introduced in Germany. Also, some amendments to the tax procedure rules have been proposed. According to the new law, portfolio dividends for shareholdings of less than 10%, measured
See MoreBrazil: Increase in revenue limit to opt for presumed profit method
The government of Brazil has again increased the gross income limit for companies to opt for taxation under the presumed profit regime. Companies electing to use the presumed profit method are taxed on a statutory rate applied to their gross
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 MoreUK: HMRC analyses data on tax schemes
The UK tax authority HMRC has received information indicating the extensive use of tax schemes to hide assets in overseas locations and it is working with the governments of Australia and the US to analyze a large amount of data. The data indicates
See MoreCanada: Reforming Temporary Foreign Worker program
Currently, Canadians have raised concerns about the Temporary Foreign Worker Program. A review of the Temporary Foreign Worker Program has been incorporated in the Economic Action Plan 2013 and legislation has been enacted to change the rules. It
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 MoreGermany: Amendments to the taxation of portfolio dividends
A new law in respect of dividend taxation was published in the Federal Gazette on 21 March 2013. This law has been introduced following a decision of the European Court of Justice in 20 October 2011 which required a review of the taxation of
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