Greece: Refund of non-final dividend withholding tax
The Public Revenue Authority has published a Document ΔΕΑΦ Β' 1135136 on 15th September 2016 for providing clarifications on the likelihood of a refund of non-final dividend withholding tax paid by legal entities on dividends received. In
See MoreBulgaria: Draft bill on mandatory electronic filing of tax returns
The Finance Ministry has published a draft modifications to the corporate and personal income tax reporting rules, mandatory electronic filing of corporate and personal income tax returns and simplified rules for filing corrective tax returns on
See MoreItaly: Publishes new guidance on CFC regulations
The Italian Tax Authorities issued Protocol No. 143239 (the Protocol) on 16 September 2016, providing further clarifications on CFC legislation, as recently amended by Legislative Decree No. 147 of 14 September 2015 and Law No. 208 of 28 December
See MoreFrance-announcement of decrease in income tax rates in 2017 Budget
The government of France announced that the current corporate income tax rate of 33.33% will be reduced in the 2017 fiscal Budget. Starting from 2017, a lower rate of 28% will be applicable to small and medium-sized enterprises (SMEs) for profits
See MoreG20 leaders comment on tax policy
The final communiqué from the G20 summit held in Hangzhou, China on 4 and 5 September 2016 began by noting that although the global economy is recovering from the crisis growth is still relatively weak. New sources for growth are emerging but
See MorePoland: Parliament passes amendments to the income tax laws
The lower chamber of the Polish Parliament (Sejm) approved a bill amending both the corporate income tax act and personal income tax on 22 July 2016.The following legislation and regulation changes will come into effect on 1 January 2017. Small
See MoreDenmark: Danish Assessment Board issues ruling on profit allocation to permanent establishment
The Danish Assessment Board gave its ruling on 16 August 2016, in the case of SKM2016.353.SR on the correct profit allocation to a permanent establishment (PE) in the form of a construction company. Facts of the case: The taxpayer is a foreign
See MoreCyprus: Tax incentives for innovative and start-up companies
The Council of Ministers approved a package, on 27 July 2016, of tax incentives intended to boost innovative and start-up companies. The incentives include the package of an exemption of up to 50% of the taxable income of the investor for
See MoreFinland: Ministry of Finance published budget proposal for 2017
The Ministry of Finance published its proposal for Budget 2017 on 12 August 2016. The tax measures will be discussed by the government on 31 August and 1 September 2016. Details of the tax measures are summarized below. The possibility for setting
See MoreLuxembourg: Government submitted draft law on CbC reporting to the Luxembourg Parliament
Recently the Luxembourg Government submitted draft law n°7031 on country by country (CbC) reporting to the Luxembourg Parliament. The draft law is in accordance with a European Union (EU) Directive of 25 May 2016 requiring all EU Member States
See MoreUK: Stamp duty land tax changes
On 10 August 2016 the UK launched a consultation on changes to the Stamp Duty Land Tax (SDLT) filing and payment process. The government is inviting comments from interested parties by 7 October 2016. SDLT is charged on the freehold or leasehold
See MoreSweden: Transfer pricing guidance updated with BEPS
The tax authorities issued an updated version of the Swedish Transfer Pricing guidance on July 2, 2016. The guidance has been updated with the final report on aligning Transfer Pricing outcomes with value creation (Actions 8-10) of the Action Plan
See MoreCzech Republic: Announcement regarding country by country reporting
The Finance Ministry of Czech has made an announcement on 11th August 2016 that it started a public consultation on a bill which would introduce changes to the Law on International Cooperation in Tax Administration. In particular, the bill would
See MoreSocial Security Agreement between Bulgaria and Montenegro ratified
The Social Security Agreement (2016) between Bulgaria and Montenegro has been ratified by Bulgaria on 26th July 2016, by way of Decree No. 259 that was published in Official Gazette No. 61 of 5 August 2016. Once in force and effective, the new
See MoreDTA between Czech Republic and Iran enters into force
The Income Tax Treaty (2015) between Czech Republic and Iran has been entered into force on 4th August 2016 and it generally applies from 1st January
See MoreGreece: Filing of amending tax return after expiry of statute of limitation period
The Public Revenue Authority (PRA) has released Circular POL 1114 on 22nd July 2016 to provide clarification regarding the filing of an amending tax return following the expiry of the statute of limitation period. The Circular says that Opinion No.
See MoreUK: Interest rates for late payments reduced according to base rate of Central Bank
On 4 August 2016, the Bank of England reduced the base rate to 0.25%. As a result, on 5 August 2016, HMRC announced that interest rates for late payment will be reduced with effect on: 15 August 2016 for quarterly installment payments; and 23
See MoreIreland published new APA guidelines
The Irish Revenue published bilateral advance pricing agreement guidelines on June 23 relating to the operation of Ireland’s APA program, which is effective for applications received on or after July 1, 2016. The guidance outlines the framework of
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