Czech Republic: New Decree on Low Value Adding Services
The General Financial Directorate (D-10) has issued the new Decree related to Low Value Adding Services took into effect on January 1, 2013 and it will relief qualifying taxpayers from preparation of full-phase transfer pricing documentation and
See MoreUK: offshore employment intermediaries
A consultation document has been issued by the UK government proposing measures to deal with issues arising from the use of offshore employers of workers based in the UK to avoid tax and national insurance contributions on wages. The consultation
See MoreUK: Consultation on loan relationships and derivative instruments
The original loan relationships rules issued by the UK government in the 1990s modernized the treatment of debt instruments by aligning the tax treatment more closely with the accounting treatment. However in the meantime the financial world has
See MoreArgentina: New process for determining “tax haven” jurisdictions
Argentina’s tax authority (AFIP) has issued a decree introducing new criteria for when to consider countries as “tax haven” jurisdictions for transfer pricing purposes. This Decree was published on May 30, 2013. The Decree states that the AFIP
See MoreCzech Republic: Proposals on dividends, stock gains and increased R&D
The Czech Republic government has submitted its long-discussed proposals on April, 2013 to “re-codify” the tax laws to the Chamber of Deputies with a proposed effective date of January 1, 2014. The main proposals are summarized below: Dividends,
See MoreLuxembourg’s Corporate Tax Plans made public
The Luxembourg Government has uncovered some details of its future corporate tax plans. Increasing the rate of business tax has been ruled out by the Government. They have however confirmed plans to further simplify and modernize tax procedures for
See MoreEgypt: New Tax Law
A new tax law was signed by the Egyptian president on 21 May 2013. The new tax law cuts the amount of tax paid by those on lower incomes and this is intended to improve their living conditions. According to the new law anyone who earns EGP 5,000 or
See MoreKorea: Foreign exchange profit taxable as dividend income
Korea’s high court has issued a judgment in a case where a taxpayer received an amount less than the principal investment on the sale of participations in Japanese funds, which was offset to some extent by foreign exchange gains from the strength
See MoreGermany: 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 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 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 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 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 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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