Philippines- to issue Advance Pricing Agreement (“APA”) procedures
First APA procedures to be released by the Bureau of Internal Revenue (“BIR”) in the Philippines. In order to meet the criteria for tax collection targets, the BIR is making considerable resources available in order to develop transfer pricing
See MoreAzerbaijan: Transition to the Modern Model of the Concept of Tax Partnership Tax Control System with Horizontal Monitoring
The costly traditional tax control system is based on the principles of taxation established 55-60 years ago. The traditional tax control system is costly since closely exerting control in pursuit of reassurance of compliance imposes a great
See MoreNew Russian CFC and anti-avoidance legislation
The amended draft law regarding controlled foreign companies and other anti-offshore measures has done most valuable changes in the field of foreign tax structures and tax avoidance. This law has publicly available on 27 May, 2014. It highlights
See MoreUS: Poor Policy for IRS Tax Enforcement-TIGTA
The Treasury Inspector General for Tax Administration (TIGTA) recently released a report on actions taken by the United States Internal Revenue to collect individual Federal income, Social Security, and Medicare taxes unpaid by businesses were not
See MoreCzech Republic: Small business supports income tax plans of government
Small businesses in the Czech Republic have said that they allow Government plans to change the Income Tax Act as part of the country's new Convergence Program during the period 2014-17.The proposals include a CZK1.2m (USD59,500) cap on flat-rate
See MoreUS Taxpayers Not Sensitive To State Income Tax Rates
The US Center on Budget and Policy Priorities has put together a report indicating that people relocating within the US do not generally regard State taxation as an important driver in their decision. This is the case even though there can be
See MoreUS Businesses Urge Two-Year Renewal of Tax Extenders
In the US the Business Roundtable (BR) has written to the Senate in relation to certain tax issues. The BR is a business grouping of CEOs from large US companies who have USD 7.4 trillion in annual revenues and together make up more than a third of
See MoreNorway: Regulations regarding exemptions to the interest
On 24 April 2014, Norway’s Ministry of Finance issued regulations regarding exemptions to the interest deduction limitation rules. Under regulations issued in April 2014 certain securities transactions are exempt from the interest restriction
See MorePortugal’s Socialist Party Would Restore Hospitality Reduced Rate
Portugal's Opposition Socialist Party (PS) leader, has promised to return the value-added tax (VAT) rate on the restaurant and catering industry to the lower rate of 13 percent if it wins the elections due to be held in 2015. The tariff was
See MoreMexico – Details of hydrocarbon tax in energy reform proposals
Mexico has announced proposals that would change the rules in respect of the taxation of amounts relating to hydrocarbon exploration and extraction. The rules would take effect from 1 January 2015. The additional government revenue would be raised
See MoreLuxembourg: Rules Out Top Tax Rate Rise
The Luxembourg government is planning to raise more revenue in the next few years by putting together a package that will include some tax rises. The Finance Minister has recently clarified however that the highest rate of income tax is not to be
See MoreIrish Personal Income Tax Cuts may be Needed
The American Chamber of Commerce Ireland has suggested that the high marginal individual income tax rates in Ireland combined with the low threshold for the highest rate create an obstacle to attracting key personnel. This also causes a cost burden
See MoreChina: Issues circular to clarify corporate income tax incentive
On 25 March 2014, China’s Ministry of Finance and State Administration of Taxation (SAT) jointly issued a circular, Caishui No. 26 (Circular 26) to clarify the criteria for the 15% preferential corporate income tax (CIT). A lower 15% incentive
See MoreGerman States Agree Tougher Tax Regularization Rules
German federal state finance ministers have discussed improvements to the tax system and have decided on action to strengthen the “declaration of non-compliance” that permits residents to regularize their tax affairs without the possibility of
See MoreEU: Issues opinion regarding cross-border intra-company transactions within a VAT group
On 8 May 2014, the Advocate General (AG) of the Court of Justice of the European Union (CJEU) issued an opinion in the case of Skandia America Corporation USA, Sweden branch (C-7/13). The questions referred to the CJEU by the Swedish court related
See MoreColombia: Rulings regarding the application of CREE tax to companies in liquidation
Colombia’s National Tax Authority (Dirección de Impuestos y Aduanas Nacionales – DIAN) has explained through Ruling No. 23001 that when a company is in liquidation it is still subject to the fairness tax (Impuesto sobre la renta para la equidad
See MoreUS: IRS eases enforcement for FATCA compliance for some taxpayers
In Notice 2014-33, the IRS has announced that it will treat calendar years 2014 and 2015 as a transition period for purposes of enforcing and administering implementation of the Foreign Account Tax Compliance Act (FATCA) by all withholding agents
See MoreSouth Africa: Issues new VAT rules
The South African Revenue Service (SARS) has on 2 May 2014 issued a new regulation setting out the circumstances under which indirect exports may qualify for zero rating and explaining when a Value-Added Tax (VAT) refund may be due on the export of
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