Germany: 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
See MoreUK: HMRC announces widespread compliance with real time information
Most UK employers are now required to report their information on wages and deductions under the Pay as you Earn (PAYE) scheme in real time. The UK tax authority HMRC announced last week that more than 680,000 employers have begun reporting PAYE in
See MoreUK: report on the role of large accountancy firms in tax avoidance
The UK’s Parliamentary Accounts Committee (PAC) has issued a report entitled “Tax avoidance: the role of large accountancy firms” criticizing the close relationship between accountancy firms and the tax authorities. The practice of seconding
See MoreSweden: tax proposals in 2013 spring budget
The government of Sweden submitted to Parliament a budget bill on 15 April 2013 that proposes domestic tax changes. The measures include improving incentives to work, strengthening the income tax credit further and increasing the lower threshold for
See MoreBelgium: New tax measures for 2013
Belgium’s Council of Ministers recently reached agreement on new tax measures for 2013. The Belgian government has already confirmed plans to increase the minimum wage and to reduce employer contributions from April 1. These measures are intended
See MoreNorway: Interest deduction limitation proposed
On 11 April 2013 the Norwegian Ministry of Finance published a legislative proposal and invited public submissions on the introduction of an interest deduction limitation for loans between related persons. The proposed limitation applies where there
See MoreUS: Public comments requested on branch profits tax for foreign corporations
The US Treasury Department and the Internal Revenue Service (IRS) are requesting comments concerning regulations TD 8223 (Branch Tax), TD 8432 (Branch Profits Tax) and TD 8657 (Regulations on Effectively Connected Income and the Branch Profits
See MoreSouth Africa: Tax measures included in 2013 budget
Certain tax proposals presented on 27 February 2013 in South Africa’s annual budget are summarized below: There were no tax increases but there was a substantial increase in fuel levies of 23 cents from April 2013. There was no specific mention of
See MoreJapan: 2013 tax reform bill has been passed
Japan’s 2013 tax reform bill passed on 29 March 2013 and the key changes are related to corporate taxation. They include the introduction of a tax credit for increased salaries paid to employees; the introduction of a tax credit / special
See MoreIreland: Finance Act 2013
The Irish Finance Bill 2013, which was published on 13 February 2013, was enacted on 27 March 2013 as the Finance Act 2013. Modifications have been made to the tax regime for start-up companies. These companies currently are not required to pay
See MoreFinland: Government’s 3-Year Tax Plan
The Finnish government has formed a new 3-year spending plan to respond to the current decline in the Finnish economy. The plan covers the years from 2014-2017. The main key points of the plan are as follows: • Corporate income tax will be
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