UK: Consultation on changes to double tax treaty passport scheme
The UK imposes withholding tax of 20% on interest paid to overseas lenders. This rate is reduced under some double tax treaties and in this case HMRC can issue a notice directing the UK borrower to apply the reduced rate of withholding tax to
See MoreCzech Republic and U.S. : Protocol to social security agreement enters into force
The amending protocol of Social Security Agreement (2007) between Czech Republic and United States has been entered into force on 1st May 2016, which was signed on 23rd September 2013 and this protocol generally applies from 1st May
See MoreCzech Republic and Tunisia: Social Security Agreement signed and approved
The Social Security Agreement between Czech Republic and Tunisia has been approved by upper chamber of parliament (senate) of Czech Republic on 6th April 2016, which was signed in Prague on 20th November
See MoreItaly: Enacted New Investment Tax Ruling Procedure
The Ministerial Decree of 29 April 2016, issued by the Ministry of Economy and Finance, was published in the Official Gazette No. 110 to enact implementing rules with respect to the tax ruling procedure for new investments recently introduced by
See MoreBelgium would introduce Cbc reporting and transfer pricing documentation requirements
A draft law that would introduce country-by-country reporting and formal transfer pricing documentation requirements at present is in the process of being finalized in Belgium. Cbc reporting Belgium has proposed draft legislation to introduce the
See MoreNorwegian Government Issued its Proposal for Implementation of Country-by-Country Reporting
The Norwegian Government has sent its draft bill on the domestic Country-by-Country (CbC) reporting rules to the Norwegian tax authorities. As per the proposal, all multinational groups with annual consolidated group revenue equal to or exceeding
See MoreGreece: Amending Income Tax Law publishes in the Official Gazette
The Income Tax Law No. 4386/2016 (amended) has published in the Official Gazette on 11 May 2016 and according to the new law which replaces article 22(1) of the Income Tax Law, the expenses for scientific and technological research are deductible
See MoreDenmark: Publishes new transfer pricing documentation guidelines
The Danish Ministry of Taxation issued two Orders : BEK nos. 401 and 402, on 28 April 2016, concerning transfer pricing documentation. The new documentation guidelines BEK no. 402, which will replace the previous guidelines of 24 January 2006 (BEK
See MoreECJ ruling on VAT on immovable property
On 28 April 2016 the European Court of Justice (ECJ) gave its preliminary ruling in the case Staatssecretaris van Financiën v. Het Oudeland Beheer BV . The case had been referred to the ECJ by the Hoge Raad der Nederlanden (Netherlands Supreme
See MoreGreece: Circular of Corporate income tax return for 2015 released
The Public Revenue Authority released Circular POL 1049/2016 providing clarifications and examples as regards completion and filing of 2015 tax returns by legal entities subject to income tax on 20 April 2016. The Circular is accessible on the
See MorePortugal: State Budget 2016 approved
On 30 March 2016, the State Budget 2016 (Law 7-A/2016) of Portugal has been promulgated by the President of the Portuguese Republic and published in the official journal Diário da República. Additionally, on 5 February 2016, further budget
See MoreDenmark: Plans for the introduction of alternative dispute resolution for TP cases
The Minister of Taxation announced on 2 May 2016, for transfer pricing cases they are planning for the introduction of alternative dispute resolution (ADR) system. The introduction of ADR is considered essential in order to assurance that transfer
See MoreSweden Proposes Implementation of BEPS 13
The Swedish Tax Agency (STA) has proposed to implement transfer pricing documentation and Country-by-Country (CbC) Reporting. As per the proposal, the Master File reporting obligations will be applicable to MNEs that have more than 250 employees and
See MoreECJ: Advocate General rules on conditions for VAT exemption on intra community supply
The Advocate General of the European Court of Justice (ECJ) ruled on 6 April 2016 in the case Josef Plöckl v Finanzamt Schrobenhausen. The case had been referred to the ECJ for a preliminary ruling on the following question: Do article 22(8), the
See MoreCzech Republic: Senate approves criminal code amendment
The Senate has approved an amendment on 27th April 2016 to the Criminal Code to the effect that even the act of preparing for tax evasion is a criminal offense. The amendment must be signed by the President for becoming law. The objective of this
See MoreSlovenia: publishes proposal for amendments to the corporate income tax law
Recently, the government published several proposals for amendments to the individual and corporate income tax laws with the aim of balancing the tax burden between companies and individuals. According to the proposals, the corporate income tax
See MoreEU proposals on country by country reporting
In the Action Plan on a Fairer Corporate Tax System issued in March 2015 the European Commission proposed to implement in the European Union (EU) the proposals under Action 13 of the OECD’s action plan on base erosion and profit shifting (BEPS).
See MoreIreland imposed surcharge for late returns
On 14 April 2016, the Irish Revenue published eBrief on the surcharge for late submission of returns. Section 1084 TCA 1997 imposes a surcharge on any taxpayer, individual or corporate, for the late filing of a tax return. If a return is not
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