United States: trust residency regulations
The US Treasury Department and the Internal Revenue Service (IRS) have requested comments on the existing final regulations (TD 8813) that provide guidance on determining the residence of a trust for US tax under section 7701 of the US Internal
See MoreUkraine: Transfer pricing report
The Ministry of Taxes and Charges has issued the official form for the transfer pricing report under Ukrainian law, and has clarified the procedures for completion. The documents were approved by Ministry of Taxes and Charges Order No.
See MoreCanada: New Anti-Avoidance Program
The Canada Revenue Agency (CRA) has announced the Offshore Tax Informant Program (OFTP) that offers financial rewards for information that helps address major international tax non-compliance. Rewards will be paid to individuals for evidence with
See MoreAustria: Tax Reform Working Group
The Austrian Government has set up a working group for tax reform, with a view to submit reform recommendations by the end of 2014. The specific reform objectives have already been set out in the coalition agreement, and the planned reforms will
See MoreAustria: draft 2014 bill amending Tax Acts
The Austrian Ministry of Finance, published the 2014 Tax Amendment Act (Abgabenänderungsgesetz 2014; AbgÄG 2014), on 9 January 2014. This amending law will make changes to certain Austrian Tax Acts, as follows: Limiting tax deductibility of
See MoreDenmark: Updated guide on expatriate regime
The Danish tax administration has published, on 15 January 2014, an update of the guide for taxation of foreign researchers and key employees. This provides the amounts and rates applicable in
See MoreSouth Africa: Tax Administration Laws Amendment Act 39 of 2013 promulgated
The Tax Administration Laws Amendment Act, 2013, has been promulgated as Act 39 of 2013 on 16 January 2014. The Act amends the Transfer Duty Act, 1949; the Income Tax Act, 1962; the Customs and Excise Act, 1964; the Value Added Tax Act, 1991; the
See MoreRussia: Ministry of Finance clarifies patent system taxation issues
The Ministry of Finance published Letter No. 03-11-09/55604 on 17 December 2013 which sets out the maximum and minimum thresholds of potential annual income to apply with regard to the patent system of taxation. The MoF also clarified that under
See MoreFrance- Transfer Pricing Rules
Draft legislation introducing a presumption that profits are received if functions and risks are transferred to a foreign related party, unless arm's length remuneration is paid, has been struck down by the Supreme Court and will not be implemented
See MoreLuxembourg: Government announces key fiscal policy agenda
The new Luxembourg government published components of its future fiscal policy on 2 December 2013. The government will focus on structural reforms in three major areas: an examination of public expenditure, measures to promote economic growth, and
See MoreAzerbaijan: 2013 Tax Revenues
Azerbaijan’s Ministry of Taxes has reported 2013 tax receipts to be AZN6.66bn, an increase from the AZN6.025bn collected in 2012. The greatest contribution came from profit tax (AZN2.37bn), followed by value-added tax (AZN1.72bn), while individual
See MoreKenya: National Social Security Fund Act 2013 enacted
The National Social Security Fund (NSSF) Act was passed by Parliament on 24 December 2013 and applies from 10 January 2014. The NSSF Act will increase the social security contributions by both the employer and the employee, with a goal to increase
See MoreTurkey: Special consumption tax changes for 2014
Turkey’s Council of Ministers have issued Resolution 2013/5761, that revises and/or specifies the special consumption tax (SCT) rates and amounts to be applied effective from 1 January 2014. These revise the SCT rates for vehicles, for beer and
See MoreItaly: Financial Transaction Tax (FTT) annual return model published
The Italian tax administration has issued the final Financial Transaction Tax (FTT) annual return model and the related instructions under Protocol No. 2013/154577. The FTT return should be filed by 31 March of every year, subject to a de minimis
See MoreBelgium: New tax rules on notional interest, small companies and withholding tax
The Official Gazette issue of 31 December 2013 notifies some new tax rules. The first measure aligns the rules relating to notional interest deductions (NID) with the judgment of the European Court of Justice in the Argenta Spaarbank case. The NID
See MoreFinland: decree on blacklist countries updated
The Ministry of Finance of Finland published Decree No. 1284/2013 on 31 December 2013. This covers countries where the tax burden differs significantly from that in Finland; the blacklist applies in implementation of the controlled foreign company
See MoreBulgaria: Companies located in “preferential” jurisdictions banned from certain transactions
Bulgaria has enacted a new law, effective from 1 January 2014 which prevents companies located in “preferential tax regime jurisdictions” (and persons related to such companies) from receiving public funds, participating in privatizations in
See MoreNetherlands: Relief, clarifications under FATCA
The Netherlands government has announced completion of a memorandum of understanding (MOU) to provide relief and clarify the intergovernmental agreement (IGA) for automatic exchange of data between the Netherlands Belastingdienst and the US IRS. The
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