EU Joint Transfer Pricing Forum meeting in February 2016
The next meeting of the EU Joint Transfer Pricing Forum (EU JTPF) is scheduled for 18 February 2016. The EU JTPF aims to provide tools for practical application of transfer pricing rules in the EU and ensure efficient transfer pricing
See MoreIMF Technical Note on introducing a GAAR
On 31 January 2016 the IMF issued a technical note on ensuring that a general anti-avoidance rule (GAAR) achieves its purpose. Many countries have either introduced a GAAR or are considering its introduction, which the objective of combating
See MoreUK: Changes to Employment Allowance
Following a consultation that closed on 3 January 2016 the UK is to implement changes to the conditions for eligibility for the employment allowance. This allowance reduces the liability for employer’s national insurance contributions and amounts
See MoreUK: Double tax agreement with Kosovo
The double tax agreement between the UK and Kosovo which was signed on 4 June 2015 entered into force on 16 December 2015. The agreement takes effect in Kosovo from 1 January 2016 and in the UK from 1 January 2016 for withholding tax; for
See MoreUK: Double taxation agreement with Croatia
The double taxation agreement (DTA) between the UK and Croatia which was signed on 15 January 2015 entered into force on 19 November 2015. The agreement takes effect in the UK from 1 January 2016 for withholding tax; for corporation tax from 1 April
See MoreUK: Memorandum of Understanding on Northern Ireland Corporation Tax
A Memorandum of Understanding on the Northern Ireland Corporation Tax (NICT) was published by HMRC and the Department of Finance and Personnel for Northern Ireland (DFPNI) on 7 January 2016. The transfer to the Northern Ireland Assembly of the
See MoreMalaysia: IRBM highlights key steps in response to BEPS
The Inland Revenue Board of Malaysia (IRBM) has released a statement highlighting the key steps taken by the Government to overcome base erosion and profit shifting (BEPS) and transfer pricing abuse. The statement was released in the Commonwealth
See MoreUK: Call for evidence on cash and the hidden economy
The hidden economy has generally been understood as an economy that uses cash to avoid leaving a record of transactions. Recently the decline in the use of cash within the UK economy has been highlighted as consumers and businesses use other methods
See MoreFrance-Administrative Supreme Court requests a ruling from the Constitutional Court regarding Parent- Subsidiary Directive and reverse discrimination
The Administrative Supreme Court (Conseil d'État) of France had requested on 12 November 2015, a preliminary ruling from the Constitutional Court (Conseil constitutionnel) in Case No. 367256 related to the conformity to the Constitution of the
See MoreIndonesia: Revised Debt-to-Equity Ratios for 2016
As per the regulation No. 169/PMK.010/2015 issued by the Ministry of Finance, the debt-to-equity ratio under the “thin cap” rules is set at 4:1 maximum for fiscal year 2016. Indonesia’s thin capitalization rules regulate the deductibility of
See MoreGhana: Finance Minister Presented To Parliament “Income Tax Bill 2015”
The Deputy Minister for Finance submitted the Income Tax Bill 2015 to the Parliament on 30 July 2015. Government is seeking to broaden the tax base and reorganise the various income tax law provisions to simplify them and make them more
See MoreMexican Tax Administration Service Publishes Revised Software Version of Appendix 9
The Mexican Tax Administration Service has published on its website the revised software version of Appendix 9 “Information on operations with foreign related parties,” of the Multiple Disclosure Return. This is an informational
See MoreEU JTPF Considers the Arbitration Convention and EU Transfer Pricing Documentation
The EU Joint Transfer Pricing Forum (JTPF) met on 12 March 2015. Following the consideration of information from the European Commission on current ongoing issues the Forum considered a revised draft of the final report on improving the functioning
See MoreVietnam: Related party transactions form replaced
As per prior guidance of Ministry of Finance, taxpayers need to use Form 03-7/TNDN to disclose their related-party transactions from the tax period beginning 1 January 2014. Tax authority issued Form 03-7/TNDN as a new form which replaces existing
See MoreUkraine: State Tax Service Clarifies Amendments of the Tax Code
The State Tax Service issued a letter on 21 January 2015 clarifying the latest amendments to the Tax Code in relation to taxation of pensions, interest on bank accounts, dividends, prizes and winnings. Details of the clarification; From 1
See MoreJapan Publishes New Consumption Tax Plans for Foreign E-services
Japan has published new plans to subject the supply by foreign providers of electronic services to their consumers to 8% Consumption Tax. This should come into place from 1 October 2015. Here is the summary of plans: Changes from the origin to
See MoreNorway & Bulgaria: DTA ratified by Norway
Norway has ratified the Bulgaria - Norway Income Tax Treaty of 2014 on 4 December 2014. The new treaty will replace the Bulgaria - Norway Income and Capital Tax Treaty (1988) as soon as it enters into force and is effective in both
See MoreItaly & Mexico: Amended protocol to DTA approved by Italian Parliament
The Italian Parliament has approved the amended protocol to the Italy - Mexico Income Tax Treaty of 1991 on 18 December 2014 and it was signed on 23 June 2011. Further details will reported
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