Poland: Amendment on the Advance Pricing Agreements
Poland’s Ministry of Finance proposed changes on 11 June 2013 that might amend the provisions concerning advance pricing agreements (APAs) if sanctioned. Changes in the APA - Extended the scope of transactions to APAs by repealing current law
See MoreFrance: IGF recommends strengthening control of transfer pricing
The French tax authorities released a report on 11 June 2013 regarding recommendations aimed at strengthening existing transfer pricing rules applicable to international groups in France, to better combat tax optimization and avoidance by
See MoreECJ: Ruling on freedom of provision of services by banks
The European Court of Justice (ECJ) ruled on 6 June 2013 in Commission v Belgium (C-383/10) that Belgium had failed to fulfill its responsibilities under Article 5 of the Treaty on the Functioning of the European Union (TFEU) and Article 36 of the
See MoreECJ: Finland refers a question on VAT on electronic publications
The Supreme Administrative Court of Finland on 23 April 2013 asked for a ruling from the European Court of Justice (ECJ) in respect of the neutrality principle and its implications for the Finnish VAT on books in electronic form. The question put
See MoreUK: Amendments to the tax treaty passport scheme
The tax treaty passport scheme was introduced from September 2010 to allow a simplified clearance scheme for taxpayers applying for reduced rates of withholding tax on interest under a double tax treaty. An overseas corporate lender in a country
See MoreUK: offshore employment intermediaries
A consultation document has been issued by the UK government proposing measures to deal with issues arising from the use of offshore employers of workers based in the UK to avoid tax and national insurance contributions on wages. The consultation
See MoreUK: Consultation on loan relationships and derivative instruments
The original loan relationships rules issued by the UK government in the 1990s modernized the treatment of debt instruments by aligning the tax treatment more closely with the accounting treatment. However in the meantime the financial world has
See MoreSpain: New forms and procedures to submit CIT tax returns approved
The Ministry of Economy and Finance has approved by Order HAP/864/2013 of 14 May 2013, the new forms, procedures and the stipulated periods for submission of returns for the corporate income tax (CIT) and non-resident income tax returns for PEs and
See MoreSlovenia: VAT rates increased
Amendments and supplements to the Act on the implementation of the Budget for the years 2013 and 2014 (the Act) were published in the Official Gazette (Uradni List, No. 46/2013) of Slovenia On 29 May 2013 on June 5, 2013. The government of Slovenia
See MoreSlovenia: Modified Corporate Income Tax Law proposed
The Ministry of Finance on 20 May 2013 published a draft law on modifications to the taxation of companies. The proposal does not implement the previous plan of a further reduction in tax rates to 15 percent and instead proposes that the 17 percent
See MoreUK: Terms of Reference issued for GAAR advisory panel
The legislation in respect of the General Anti Abuse Rule (GAAR) in the Finance Bill 2013 provides for the appointment of a GAAR advisory panel. The panel is to consider and approve HMRC’s guidance on the GAAR. It is also required to consider
See MoreUK: Strengthening the code of practice on taxation for banks
The HMRC released a consultation document on 31 May 2013 in respect of amendments to the code of practice on taxation for banks. Comments on the proposed changes are invited by 16 August 2013. The provisions of the code cover the required practices
See MoreUK: HMRC guidance the Seed Enterprise Investment Scheme
The HMRC published a series of answers on 28 May 2013 to frequently asked questions about the Seed Enterprise Investment Scheme (Seed EIS). The scheme has been applicable in respect of shares issued after 6 April 2012. The Seed EIS was set up to
See MoreUK: Consultation on the VAT treatment of refunds by manufacturers
The UK issued a consultation paper on 31 May 2013 in respect of the value added tax (VAT) treatment of refunds paid directly by manufacturers to consumers. The current UK VAT law permits a business that is in a direct relationship with a customer to
See MoreNetherlands and China tax treaty is signed
A new China and Netherlands Income Tax Treaty was signed on 31 May 2013 in Beijing. Once in force, the new treaty will replace the current Income Tax Treaty of 1987. Neither treaty party can terminate this treaty before 30 June of the calendar year
See MoreHungary: Draft bill on the proposed changes to transfer pricing reporting obligations
The Ministry of National Economy of Hungary had announced a draft bill in March 2013. The draft bill proposed significant changes to the reporting requirements regarding the determination of arm’s length prices. According to the proposed changes
See MoreCzech Republic: Proposals on dividends, stock gains and increased R&D
The Czech Republic government has submitted its long-discussed proposals on April, 2013 to “re-codify” the tax laws to the Chamber of Deputies with a proposed effective date of January 1, 2014. The main proposals are summarized below: Dividends,
See MoreLuxembourg’s Corporate Tax Plans made public
The Luxembourg Government has uncovered some details of its future corporate tax plans. Increasing the rate of business tax has been ruled out by the Government. They have however confirmed plans to further simplify and modernize tax procedures for
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