Spain: National court decides intra-group debt transaction as fraud of law
The Spanish National Court decides the case of Sabic Innovative against the tax administration (Appeal 367/2010) as fraud of law. The Court ruled that the intra-group debt transaction is usually tax-driven and did not have an economic or business
See MoreSlovak Republic: plans to raise its tax revenue by 0.3% of GDP in 2014
Slovak Republic has planned to raise its tax revenue in 2014 than previous year forecast. The government forecast to collect 189 million Euros ($259 million) or about 0.3 percent of GDP which is more than it forecast in the budget as the government
See MoreRussia: Clarification regarding tax treatment
On 18 December 2013 the Russian Ministry of Finance (MoF) published Letter No. 03-08-05/55702, clarifying the tax treatment of contractual penalties paid by a Russian company to a Ukrainian company for violation of the contractual terms. According
See MoreRussia: Clarification regarding residence rules of partnership income
The Russian Ministry of Finance (MoF) allotted Letter No. 03-08-05/1229,on 17 January 2014, clarifying whether income received by a US partnership may be subject to tax according to the Russia–United States Income and Capital Tax Treaty (1992).
See MorePhilippines: Importers Require Tax Authority Accreditation
The Philippines' Department of Finance has issued a department order requiring all importers to be accredited by the Bureau of Internal Revenue (BIR) before they can obtain an import permit from the Bureau of Customs (BOC). This measures aims to
See MorePeru – Reduced rate of general sales tax
Peru’s tax administration issued a resolution concerning the reduced rate of general sales tax on 1 February 2014. The general sales tax is charged on the purchase price of certain goods and services. The resolution will be effective from 1 March
See MoreMalta intends to amend taxation rules
Malta is intending to amend the rules relating to the taxation (and withholding tax) on amounts distributed by corporations from profits. One of the amendments will change the definition of a recipient in respect of withholding tax on distributions
See MoreMalaysia: Flat corporate tax rate introduced for SMEs which merge
On 14 February 2014, the International Trade and Industry Minister announced a flat rate of 20% for 5 years for Small-Medium Enterprises (SMEs) which have merged to form larger entities. Currently, SMEs only enjoy the reduced corporate tax rate of
See MoreKenya: Tax Appeals Tribunal Bill 2013 signed into law
The Tax Appeals Tribunal Bill 2013 was signed into law on 2 December 2013. The Act is not yet in effect and awaits the Cabinet Secretary for the National Treasury to publish its commencement date. When the Bill is passed the Tax Appeals Tribunal
See MoreKazakhstan: Finance Ministry permits to sign DTA with Slovenia
On 3 February 2014, the government of Kazakhstan gave clearance for the Ministry of Finance to sign the income and capital tax treaty with Slovenia. The agreement of the text of the draft double taxation agreement was originally announced on 13 June
See MoreCzech Republic – Coalition government’s tax policy
The agreement establishing the new government in the Czech Republic indicates that there are currently no plans to raise income taxes. With respect to corporate income tax, however, the coalition agreement mentions that a “sector tax” with
See MoreColombia – New criteria for determining large taxpayer issued
Colombia’s tax administration has issued guidance establishing new criteria for determining who qualifies as a “large taxpayer”. Being identified as a “large taxpayer” may affect specific arrangements for paying taxes, and may affect both
See MoreBulgarian government will maintain low rates of direct taxes
On February 11, 2014, a forum entitled: Government-Business: Economic Restart National Forum: was organized at the initiative of the Bulgarian Prime Minister. The forum was organized in four different panels that discussed the following
See MoreBulgaria confirms that it will keep its 20% VAT rate
The government of Bulgaria has confirmed that it will keep its 20% VAT rate for the foreseeable future as part of its flat tax policy. Bulgaria has one of the lowest VAT rates in the region. Some other countries in central Europe have been
See MoreArgentina: Income tax changes relating to share transfers and dividends
Changes have been made in Argentina to the income tax treatment of securities, the transfer of shares and dividend distributions. On 7 February 2014, Decree 2334 was published in the official gazette. This Decree implements income tax changes as
See MoreGermany: VAT rates on multiple rate supplies
The German Federal Ministry of Finance has clarified the procedures for German VAT rates on a single supply where there are different VAT rates applicable. Where a supplier is offering for a single price goods with multiple VAT rates attached, the
See MoreCroatia ratifies convention on Mutual Administrative Assistance in Tax Matters
On 31 January 2014, the Croatian parliament ratified the multilateral Convention on Mutual Administrative Assistance in Tax Matters, signed on 25 January 1988 and the amending protocol signed on 27 May 2010. This multilateral Convention is seen as
See MoreUnited Kingdom – Supreme Court addresses cross-border group losses
The UK Supreme Court on 19 February 2014 issued its judgment relating to three remaining issues in the Marks & Spencer case—i.e., the case addressing a cross-border group relief claims. The Court found that the conditions for the “no
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