Brazil – 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 MoreNetherlands – Distinction between loan interest and dividend
The Netherlands Supreme Court (Hoge Raad) on 7 February 2014 issued two decisions affecting taxpayers. The first decision related to whether a payment would be regarded as interest on a loan or as a participation dividend paid on a share capital
See MoreUS: Senate democrat leader opposes Trade Promotion Authority renewal
The US Senate Majority Leader has expressed his opposition to the Trade Promotion Authority (TPA), despite the intention of President Obama to engage with Congress to pass the legislation providing for the renewal of the TPA. This opposition to the
See MoreUS: Republican Obama Care Abolition Plan Includes New Tax Credit
The recent healthcare reforms of the Affordable Care Act, known colloquially as Obama care, have been vehemently opposed by some sections of the US Congress. Three United States senators have now released a legislative outline of how the Republican
See MoreUS: Case Made For Progressive Consumed Income Tax
In a recent editorial article the President and CEO of the American Council for Capital Formation called for consideration to be given to a change from the current income tax code to a "progressive consumed income tax" in the United States. He
See MoreUnited Kingdom – Proposals related to tax disputes and identifying scheme promoters
HM Revenue and Customs (HMRC) has issued consultation documents which include proposals for taxpayers to make accelerated payment of tax that is in dispute or subject to enquiry and for identifying “promoters” of tax avoidance schemes. The
See MoreRussia Considers Tax Break for Landlords
Russia's Economic Development Ministry has recently proposed cutting tax rates for citizens who lease their apartments. This measure aims to reduce the numbers of unregistered landlords. The proposal involves reducing the tax on rent revenues to
See MoreNetherlands – Planned pension changes
On 20 January 2014, a proposal was presented to amend pension accrual rates and impose a limit on “pensionable” income. The following measures are included in the proposed amendments: An adjustment to the maximum pension accrual rates; A cap
See MoreMexico settles issues with Maquiladoras
The President of the National Council of the maquiladora industry has commented that the sector has largely settled its differences with the Mexican government over tax issues, following the changes to the Mexican Government's tax reform bill which
See MoreIndia: Improvements to VAT compliance and administration procedures
Some improvements to the Indian VAT compliance and administration procedures have been announced to help traders. India’s VAT is a state level tax on the sale of goods. The changes include plans to reduce the number of Indian VAT audits, the
See MoreBrazil – Social Security Tax on Exports to Trading Companies
The tax department has issued guidance clarifying that revenues from the sale of products to trading companies for the purpose of export are subject to social security taxation. Normative Instruction 1436 (IN 1436) released on 9 January 2014 was
See MoreMalta – Inclusion of the individual tax proposals in budget legislation
In Malta legislation has been presented to parliament to implement measures that were presented in the government’s budget for 2014. The proposed amendments include the introduction of a new tax bracket; the extension of the parental computation;
See MoreUnited Kingdom: Partnerships, tax policy
To inquire into the draft Finance Bill 2014 as published on 10 December 2013 the House of Lords Economic Affairs Committee has established a Finance Bill sub-committee. The sub-committee will focus on two areas: The draft clauses relating to the
See MoreUnited Kingdom – Derivative contracts and anti-avoidance legislation
On 23 January 2014, draft legislation amending the rules for derivative contracts was updated by adding an anti-avoidance provision which disregards debits and credits arising from arrangements to transfer profits between group companies. The
See MoreUkraine: Tax Code Changes Included in 2014 Budget
The Ukrainian President signed the law on the state budget for 2014 on January 17, 2014. The draft law on the budget provides for changes to the country's tax code. According to the draft the value-added tax rate will remain unchanged at 20 percent
See MoreSpain to review tax system for families
Spain's Finance Minister has announced that the Government will review family tax reliefs ahead of the next tax reform. In a meeting, he has reiterated the Government's commitment to helping Spanish families and promoting equality of opportunities.
See MoreSouth Africa: Tax implications of assumption of contingent liabilities
The tax implications in relation to the assumption of contingent liabilities in partial settlement of the purchase price of assets acquired as part of a going concern have been addressed by the South African Revenue Service (SARS). The initial views
See MoreRussia considers Tax on Foreign Online Retailers
Russia is considering whether to levy a 30 percent tax on imports from foreign online retailers and restrict the number of parcels imported. The proposed tax, which would be imposed on imports worth more than RUB7, 000 (USD 202), is intended to
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