Asia Pacific – ASEAN single market in 2015 and tax incentives
Beginning in 2015, the 10 member countries of ASEAN intend to form a common market—the ASEAN Economic Community (AEC)—based on the free flow of goods, services, investment, and skilled labor and the free flow of capital. The member states of
See MoreOECD – Revised timeline for BEPS discussion drafts and public consultations
The Organization for Economic Cooperation and Development (OECD) has released a revised timeline for action relating to base erosion and profit shifting (BEPS) discussion drafts and public consultations. The first outputs under the BEPS project are
See MoreIndonesia Considers Tax Breaks for Corporate Bond Investors
Indonesia is considering help for investors in corporate bonds and is also planning to make it easier for local companies to sell shares to the public. Indonesia plans to set up tax incentives for investors in corporate bonds and also plans to
See MoreEU: European Commission presents Working Paper on Thin Capitalization Rules
The European Commission has recently published working paper N.42, entitled "Thin Capitalization Rules and Multinational Firm Capital Structure" This paper examines the impact of thin capitalization rules (that limit the tax deductibility of
See MoreRussia- Financial Services
Under Federal Law 39-FZ and 420-FZ, from 1 January 2015 interest on related party loans should be charged at market rates and documentation should be maintained to demonstrate
See MoreColombia: Thin capitalization provisions
The Colombian government issued Decree No. 3027 on 27 December 2013 to clarify thin capitalization rules under Art. 118-1 of the Colombian Tax Code; the Decree applies from 1 January 2014. Under the thin-capitalization regime, interest generated on
See MoreFrance-Canada DTA protocol approved
In accordance with initial media reports, France's lower house of parliament approved the protocol to the Double Tax Agreement signed with Canada on December 23,
See MoreNew Zealand: Legislation Brings Clarity to Tax Rules
The Government of New Zealand has been published an omnibus tax bill intended to bring significant clarity to the tax rules and make them easier for taxpayers to understand. The changes will restrict how much debt foreign investors are able to place
See MoreUSA – IRS Announces Pension Plan Limitations for 2014
On October 31, 2013, the Internal Revenue Service announced cost of living adjustments affecting dollar limitations for pension plans and other retirement-related items for tax year 2014. Some pension limitations such as those governing 401(k)
See MoreIsrael: Action required for releasing trapped profits by 11 November 2013
Only those companies have to apply the temporary partial relief from Israeli corporate income tax until 11 November 2013, who wish to release their trapped exempt profits that were accrued until December 31, 2011. Companies will have to submit their
See MoreKenya: The Revenue Authority adduces “force of attraction” rule
Kenya’s tax treaties generally follow the provisions of the OECD Model Tax Convention. However despite the expectation under the OECD Model that only profits acquire or accumulate from Kenya and attributable to the permanent establishment should
See MoreFrance: New decree enacted regarding tax incentives audit
In France Decree No. 0189 was published in the Official Gazette on 15 August 2013. The Decree provide detail information regarding the tax audit procedure implemented for the tax incentives granted within the French overseas departments (DOMs).
See MoreUkraine: Related-Party information returns to file with APA requests
The transfer pricing rules introduced by Ukraine from 1 January 2013 provide for the possibility of negotiating advance pricing agreements with the tax authorities. The Ukraine Ministry of Finance has approved an information form concerning related
See MoreBrazil: Withholding Tax Changes on Profit-Sharing Payments
Provisional Measure No 597 of December 26, 2012 came into effect on 1 January 2013.This introduces a new regime for the taxation of profit-sharing payments received by employees from their employers. The change permits employed persons to obtain up
See MoreNew plan for tax exemption for Argentina
Argentina's President Cristina Fernandez de Kirchner has taken some initiatives to increase the tax-exempt personal income tax threshold. According to the new plan, taxpayers with a gross monthly salary of up to ARS25,000 (USD5,215) will be
See MoreIncome Tax Treaty between Lithuania and Mexico enters into force
Mexico and Lithuania signed an Income Tax Treaty on 23 February 2012. The treaty has come into force on 29 November 2012, and will be applicable from 1 January 2013. Under the provisions of the treaty an enterprise will have a permanent
See MorePolish President ratifies Protocols amending Poland’s DTAs with Iceland and Luxembourg
On November 16, 2012, Polish President Bronislaw Komorowski ratified Protocols amending Poland's double taxation agreements (DTAs) with Iceland and
See MoreBrazil Eases IOF Tax
It has been published on 22 June 2012 that the Brazilian government has reduced the scope of the financial transactions tax on foreign loans after concerns about the strength of the domestic currency eased. The government had previously announced
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