EU: Issues opinion regarding cross-border intra-company transactions within a VAT group
On 8 May 2014, the Advocate General (AG) of the Court of Justice of the European Union (CJEU) issued an opinion in the case of Skandia America Corporation USA, Sweden branch (C-7/13). The questions referred to the CJEU by the Swedish court related
See MoreColombia: Rulings regarding the application of CREE tax to companies in liquidation
Colombia’s National Tax Authority (Dirección de Impuestos y Aduanas Nacionales – DIAN) has explained through Ruling No. 23001 that when a company is in liquidation it is still subject to the fairness tax (Impuesto sobre la renta para la equidad
See MoreSouth Africa: Issues new VAT rules
The South African Revenue Service (SARS) has on 2 May 2014 issued a new regulation setting out the circumstances under which indirect exports may qualify for zero rating and explaining when a Value-Added Tax (VAT) refund may be due on the export of
See MoreRomania Pursues Tax Debtors
Romania’s tax authority has commenced a pilot project aiming to ensure that medium sized businesses pay their tax arrears. Businesses are being contacted and given the options available for settling their liabilities. The intention is to
See MorePeru: Published regulation for advance pricing agreement
The tax authority's Resolution 377-2013/SUNAT, published in the Official Gazette on 29 December 2013.Accordance with the Resolution 377/2013, intention to negotiate an APA should be expressed in writing to SUNAT which must reply within 15 days.
See MoreUS – IRS Advises Taxpayers with Foreign Income
The IRS has issued instructions for /US citizens or residents who are living or working abroad, and for people in the US receiving foreign income in 2013. All income of US citizens or residents must be declared to the IRS and the rules in respect of
See MoreEU Approves UK Video Game Tax Break
The European Commission has approved the new UK tax relief for video game as being in line with EU state aid rules. The videos games tax relief is designed to give an incentive to developers of video game developers to design products that meet
See MoreAustralian Taxation Office Launches Offshore Tax Amnesty
The Australian Taxation Office (ATO) is conducting another initiative to urge taxpayers to declare understated offshore income and to revise claims for tax deductions where these are overstated. Disclosures of income are to be regarded as
See MoreUS – IRS Issues Revised Guidance on Business Expenses
The IRS has published a revised version of Publication 535 that gives guidance to taxpayers on claiming a tax deduction for business expenses. The publication contains instructions in respect of the years 2013 and 2014. This may be important for
See MoreSwitzerland Plans Stricter Rules for Biofuel Tax Breaks
The Swiss Council of States has given its approval to a bill strengthening the provisions on the eligibility of enterprises for biofuel tax breaks. Biofuels may be partly or wholly exempt from mineral oil tax provided that they conform to certain
See MoreSingapore- issues e-Tax Guide on GST Advance Ruling System
An updated e-Tax Guide has been published by the Inland Revenue Authority of Singapore (IRAS) to give guidance on aspects of the Goods and Services Tax (GST) advance ruling system and on the relevant application procedures in connection with the
See MoreRomania: New tax law to conform to EU rules
Romania has passed Law No 8/2014 to bring the tax low into line with EU provisions. The Law provides for new VAT place of supply rules for broadcasting, telecom and electronically supplied services that are similar to EU rules. The Law also reforms
See MoreUS – Supreme Court Agrees Severance Pay Is Taxable
In the US the Supreme Court has decided in favor of the IRS in a case involving the tax status of involuntary severance payments made to employees who have been laid off. The Court decided that these payments are subject to the provisions of the
See MoreFrance – Employers demand Corporate Tax Cuts
Anxious to kick-start talks on a reform of corporation tax, the President of the French employers' federation Medef, has called on the Government to lower the corporate social solidarity contribution (C3S) together with the headline rate of
See MoreChinese SAT announces new plans for the future
In a video conference held by the State Administration of Taxation (SAT) on 18 March 2014 the current work on international taxation and future plans were outlined. China has improved the legal framework within which its international tax work takes
See MoreUS – IRS Issues Virtual Currency Tax Guidance
The IRS has published guidance in respect of the use of Bitcoin and similar digital currencies. These are to be regarded for federal tax purposes as property rather than currency. This should remove uncertainty about the tax treatment of these
See MoreUK Court of Appeal rules on payment of corporation tax on VAT repayments
In a case concerning an online retail group in the UK the Court of Appeal has determined that the taxpayer must pay corporation tax in respect of VAT repayments received. The consequence of this victory for the tax authority is that many taxpayers
See MoreSpain – New tax measures for corporate debt refinancing and restructuring
Royal Decree Law 4/2014 which is effective from 9 March 2014 contains provisions in respect of corporate debt restructuring. Among the issues covered in the law are the treatment for tax purposes of capital increases through the capitalization of
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