Kenya: 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 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
See MoreAdvanced Pricing Agreement Guidelines published in Russia
On January 31 2012 it has been published that, the Russian Federal Tax Service published a letter No.ОА-4-13/85 “On Conclusion of Advanced Pricing Agreements for the tax purposes” dated 12 January 2012 on its official website. The letter is a
See MoreTax Simplification Projects Announced in UK
In order to improve and simplify the tax system, the government of UK declared two new projects as part of its ongoing work, to review pensioner taxation and employee share schemes. On 13 July 2011 the government has confirmed that the UK’s Office
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