Germany: Draft regulation for the profit attribution to PEs issued for public discussion
The draft version of a new Regulation on the attribution of profits to permanent establishments (PE Regulation) has been issued on 5 August 2013 by the German Ministry of Finance for public discussion. The main goal of the PE Regulation is to
See MoreIndia – Indian government set up its first Tax Administration Reform Commission
The Indian government set up its first Tax Administration Reform Commission on 26 August 2013. The seven-member panel is being given eighteen months to draw up its recommendations. The Commission is likely to put forward proposals for the creation
See MorePortugal: Extraordinary investment tax credit to boost investment is introduced
The Portuguese government introduced an extraordinary investment tax credit with effect from 17 July 2013. The special tax credit will be applicable to investments between 1 July 2013 and 31 December 2013, up to a limit of EUR 5,000,000. The tax
See MoreSouth Africa: Tax consequences of debt reduction transactions
South Africa’s Taxation Laws Amendment Act, 2012, includes provisions that revise the tax treatment of debt reduction transactions entered into on or after 1 January 2013. Since the objective of the new tax reduction rules is to make it easier
See MoreSouth Korea- Planning of Acquisition Tax Cuts
The South Korean Government announced on 30 August 2013 that the tax rates on home purchases would be decreased in order to encourage a rise in transaction numbers. An exemption from property acquisition tax was granted in April 2013, but the
See MoreBelgium: Introduction of “fairness tax” on companies
The Belgian government has introduced a “fairness tax” on companies. Due to compensation for losses or notional interest deductions, if companies dividends are paid and corporate tax is not paid, will be liable to pay this fairness tax. In an
See MoreBrazil: Guidance Issued on the Pricing of Interest Bearing Transactions
The Brazilian Ministry of Finance has issued an ordinance 427/2013, On 2 August 2013, which finally define and clarifies the interest rate spread and that was mentioned but not specified in Law 12.766/2012. Under Ordinance 427/2013 where the
See MoreCanada – Amends to foreign affiliate dumping rules proposed by the Government
The draft legislation has introduced on August 16, 2013, to make revisions to the foreign affiliate dumping (FAD) rules that were first declared as part of the 2012 federal budget and enacted on December 14, 2012 according to Bill C-45 and it would
See MoreChina: Eligibility of software enterprises for corporate income tax incentives
To clarify the rules concerning software enterprises that are eligible for certain corporate income tax incentives, China’s State Administration of Taxation has issued guidance on the issues arising in qualifying for these incentives. According
See MoreCroatia: Government proposes amendments to Individual Income Tax Law
The government has proposed amendments to the Individual Income Tax Law on 25 July 2013. Following the constitutional court decision these amendments provide that dividends or participation in profits obtained after 31 December 2000, but paid out
See MoreCyprus: Tax treatment of loan write-off by a financial institution
Recently guidance with respect to the tax treatment of a loan write-off by a financial institution, for the benefit of the borrower, has been issued by the tax authority of Cyprus. According to Circular 2013/14 of 30th May 2013, a partial or
See MoreFrance introduces bill on new tax incentives for entrepreneurs
The government of France introduced a Bill into the National Assembly on 21 August 2013 in relation to tax incentives for entrepreneurs in crafts, trade and small businesses. Accordingly, entrepreneurs are exempt from the additional tax on real
See MoreFrance: New deductions enacted on capital gains
The government of France issued a circular on 9 August 2013 on reductions of capital gains for individual income tax and social contributions purposes. Capital gains derived from the disposal of immovable property other than land benefit from the
See MoreIndia – CBDT Releases Drafts on Transfer Pricing Safe Harbor Rules
India’s Central Board of Direct Taxes (CBDT) released draft transfer pricing “safe harbor” rules as part of an initiative by the government to reduce the number of transfer pricing audits and protracted disputes on 14th August 2013,. Under the
See MoreItaly: Decree on Final Exit Tax has been published
The Ministerial Decree of 2 August 2013 is implementing new rules on 12th August 2013 regarding the income tax treatment of the migration of Italian companies which was published in the Italian Official Gazette n. 188/2013. According to the Decree,
See MoreLuxembourg publishes Circular on Minimum Corporate Income Tax (MCIT)
The Luxembourg tax authority published a circular L.I.R. no. 174/1 on 1 August 2013. This relates to the Minimum Corporate Income Tax (MCIT). The most significant parts of the circular are given below: Luxembourg permanent establishments are not
See MoreNew Zealand reforms the Inland Revenue Department
The New Zealand Government has announced to reform the Inland Revenue Department which intended to make it easier and less costly to taxpayers’. The first things of changes need to improvements of processes, skills and capabilities, and
See MorePhilippine: Collect taxes from online sellers
The Bureau of Internal Revenue (BIR) of Philippines’ has released a memorandum, which is ensure that it will start accumulate taxes from individuals and businesses for selling products online. This measure is already permitted under the tax law
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