UK: Autumn Budget Announcements 2017
The UK’s autumn budget measures were announced on 22 November 2017. Important measures affecting business are as follows: R & D Tax Relief The Research & Development Expenditure Credit (RDEC) rate available to companies claiming under
See MorePoland: A new version of a draft bill to amend corporate income tax law
Recently, a new version of a draft bill to amend Poland’s corporate income tax law (and also to amend the individual income tax law) was submitted to the parliament. The amendment will most likely come into effect on 1 January 2018. Main changes
See MoreColombia changes rules of amortization of intangible assets
Colombian National Tax Authority (DIAN) has published a ruling regarding the application of amortization of intangible assets. In accordance with ruling, amortization method of an intangible must be decided based on the accounting rules, as long as
See MoreIndia: CBDT issues final rules for valuation of unquoted shares
The Central Board of Direct Taxes (CBDT) on 12 July 2017 has issued a notification prescribing the method for valuation of unquoted shares for the purposes of Section 56(2)(x) and Section 50CA of the Income-tax Act 1961. The rules will be effective
See MoreOECD: Comments received on draft HTVI implementation guidance
On 5 July 2017 the OECD published comments received in relation to the BEPS discussion draft on the implementation guidance on Hard-to-Value Intangibles (HTVIs). The comments received focus on a range of points including the uncertainty arising for
See MoreChina issues new TP and MAP rules
On 1 April 2017, The State Administration of Taxation (SAT) of China published a Bulletin-6 providing new transfer pricing (TP) guidance and strengthening the Mutual Agreement Procedure (MAP) process. Bulletin 6 is effective from 1 May
See MoreSwitzerland: Parliament adopted the final Corporate Tax Reform III
On June 17, 2016, the Swiss parliament adopted the final Corporate Tax Reform III package (CTR III) to strengthen Switzerland’s competitiveness as a business location. The Corporate Tax Reform III includes several notable tax reform measures
See MoreChina: New changes of TP regulations
SAT Bulletin No. 42 published on July 13, 2016 has replaced the existing transfer pricing documentation regulations in Circular Guoshuifa No. 2, known as Circular 2. As per Bulletin 42, two parties will be considered related if they have “other
See MoreUK: Autumn Statement Includes Measures Effective from 25 November 2015
The Chancellor of the Exchequer delivered his Autumn Statement to Parliament on 25 November 2015. The measures with immediate effect from 25 November 2015 are as follows: Loans to participators, trustees of charitable trusts: This measure affects
See MoreColombia: National Tax Authority Issued Transfer Pricing Rules on Sales of Intangibles
The National Tax Authority of Colombia announced on sale transactions of intangibles subject to the transfer pricing regime. In article 260-1 of the Tax Code provides criteria for ascertaining whether two or more parties are related parties and the
See MoreChina: SAT is Seeking Public Comments on Consultation Draft for Implementing Special Tax Adjustments
On 17 September 2015, China’s State Administration of Taxation released a consultation draft circular concerning implementation measures for special tax adjustments that would replace the existing Guoshuifa No. 2 (Circular 2). Now the SAT is
See MoreUS: Treasury Department and IRS Released Temporary Regulations and Proposed Regulations to Clarify the Arm’s Length Standard
The Treasury Department and IRS released for publication in the Federal Register Temporary regulations (T.D. 9738) on 15 September 2015 to clarify the arm’s length standard and the best method rule under Code section 482 and the regulations
See MoreUruguay: New rules for depreciating intangible assets
The government of Uruguay has modified the rules for depreciating intangible assets through Decree No. 181/015 of 6 July 2015. The new rules have changed the general depreciating period for intangible assets acquired from 1 July 2015. Taxpayers
See MoreNigeria: First audit cycle under new transfer pricing regulations starts
The Federal Inland Revenue Service (FIRS) in Nigeria has built a Transfer Pricing Division on November 2013 that is accountable for the execution and administration of the Income Tax Transfer Pricing Regulations No.1 2012 (TP Regulations). This
See MoreOECD publishes comments received on intangibles
The OECD has published on its website the comments received by interested parties on its revised discussion draft on transfer pricing aspects of intangibles. The input received from more than sixty commentators will be discussed by the OECD’s
See MoreOECD issues a revised discussion draft on intangibles
For some time the OECD has been conducting a project on transfer pricing aspects of intangible assets including consideration of the definition and valuation of such assets. A discussion draft was issued on 6 June 2012 and followed up by a
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