France – Transfer pricing adjustments been recognized by the Appellate courts
The Administrative Courts of Appeal of France recently issued decisions affirming transfer pricing adjustments which are as follows: Lyon court of appeals The Administrative Appeals court in Lyon concluded that Frenchco exercised direction and
See MoreFrance – Administrative Court of Appeal of Paris denies use of secret comparables
The Administrative Court of Appeal of Paris gave its decision in Nestlé Entreprises v. Minister of Economy and Finances (No. 12PA00469) on 5 February 2013 concerning the use of secret comparables under the transfer pricing regulation, article 57 of
See MoreCanada-Luxembourg: DTC Protocol Entry into force
The Protocol amending the double taxation Convention between Canada and Luxembourg has entered into force on December 10, 2013 and was actually signed on May 8,
See MoreSigning of Protocol to DTA between Philippines and Italy
The Government of the Philippines confirmed on December 9, 2013 regarding the signing of a Protocol to the double taxation agreement (DTA) with
See MoreDTA between Cyprus and Portugal
The Cyprus and Portugal signed a double taxation agreement and this agreement will become effective from January 1, 2014, after the entry into force of the agreement on August 16,
See MoreCzech Republic – Changes regarding tax and insurance premiums
In the Czech Republic, under changes that are effective in 2014, employers will need to ready new rules regarding the taxation and insurance premiums in respect of employees. Again, there are changes to the social and health insurance premiums for
See MoreCyprus – Effort to Resolve India Tax Treaty Suspension
The government of Cyprus is taking the initiative to resolve matters regarding the suspension of provisions within the tax treaty with India. The Indian government suspended the provisions of the 1994 tax agreement on 1 November 2013, with Cyprus
See MoreBelgium: Royal Decree on tobacco tax rise
A draft Royal Decree, regarding tax rise on tobacco is approved by the Belgian Council of Ministers. As a result, the excise duty on cigarettes will be fixed at EUR 6.8914 (USD 9.2) per 1,000 pieces from 1 January 2014, and the special excise duty
See MoreBelgium: Enhancement of employers’ social security tax break
A draft Royal Decree is approved by the Council of Ministers of Belgium with a purpose to strengthen the structural reduction of employers’ social security contributions. An increased rate of structural reduction of employers’ social security
See MoreBelgium confirms withholding tax rate changes
Belgium has decided to reduce the rate of withholding tax levied on small- and medium-sized enterprise (SME) dividends from 25 percent to 15 percent; and it is a confirmation from The Belgian Prime Minister. In order to encourage entrepreneurs to
See MoreInterest income under the income tax treaty between Vietnam and France
The income tax treaty between Vietnam and France does not provide any provisions for the taxation of interest derived from transactions of loans. Recently Vietnam has provided guidelines on certain tax provisions of the treaty. According to the
See MoreUnited Kingdom: UK High Court decision on portfolio dividend tax
UK High Court decision concerns the portfolio dividend tax (holdings of less than 10%) under the previous tax law which provided double tax relief for foreign withholding taxes paid on the dividends and no relief for any underlying tax. UK has moved
See MoreTax Devolution process for Wales has been confirmed by the UK Government
The UK Prime Minister has confirmed in a press release on 7 November 2013 that the Government intends to devolve the power to set Landfill Tax and Stamp Duty rates in Wales, and to hold a referendum on devolving the income tax rate. It was announced
See MoreRomania: Amendment of income tax rate for severance payments
Romania now limits the individual income tax rate of 85% with respect to only particular severance payment. Previously it was imposed on employees who were in management position or to the members of a board of directors under an Ordinance
See MorePortugal: Gazettes Tax Regularization Decree
Decree-Law number 151-A/2013 is published in the country’s official Gazette. To tighten sanctions, it establishes an exceptional and temporary regime for the regularization of tax debt. From 2014 individuals who committed tax fraud will face
See MorePortuguese: New VAT measures in Finance Bill
A range of changes to the Portuguese VAT regime has been presented in the latest Finance Bill which would come into effect on 1 January 2014. According to the upcoming changes, taxpayers will now have the option to forgo the VAT exemption on
See MoreIncome tax treaty between Luxembourg and Laos
An income and capital tax treaty between Luxembourg and Laos has been ratified, and awaiting the exchange of instruments of ratification before the treaty can enter into force. The Luxembourg and Laos income tax treaty provides withholding tax rates
See MoreLatvia: Parliament amends the Micro-enterprise tax law
According to the amendments a natural or legal person who is a member of a partnership can’t be a micro-enterprise tax payer. The proposal will come into force from July 1, 2014 so that a partnership member can withdraw his/her membership within
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