Poland – Reviewed tax haven list, transfer pricing documentation
Poland’s Ministry of Finance proposed to change the rule and regulation containing the list of countries and territories that are identified as applying “harmful tax competition on March 8 2013”. After finalizing the changes the Polish
See MoreDanish Government plans to reduce corporate income tax rate
On 26 February 2013, the government published a document stating that it plans to reduce the corporate income tax rate to 22% (currently 25%). The reduction would be implemented gradually by reducing the tax rate by 1 percentage point between the
See MoreUK: Protocol to the double tax agreement with China
A protocol to the treaty between the UK and China was signed on 27 February 2013. This protocol amends the dividend article of the 2011 tax treaty between the UK and China which is not yet in force. Both the treaty and protocol will enter into force
See MorePoland – Changes to transfer pricing documentation, thin capitalization rules
Legislation to expand the scope of Poland’s corporate income tax law is intended to be effective in 2014. The provisions of the legislation released on February 18, 2013 include changes to the transfer pricing documentation and thin capitalization
See MoreEU: ECJ Rules on German foreign tax credit rules
The European Court of Justice (ECJ) issued a decision on 28 February 2013 in the case of Dr. Manfred Beker and Christa Beker v Finanzamt Heilbronn. A preliminary ruling from the ECJ had been requested by the Federal Finance Court. The case
See MoreGreece: Introduction of new Advance Pricing Agreement and Improvements of transfer pricing framework
Tax Law 4110/2013 was circulated in the Govt. Gazette on 23th January 2013. Aside from some major amendments on taxation of natural person and corporate income taxation, the new law includes an improvement of the Greek transfer pricing regulatory
See MorePortuguese Court’s decision in transfer pricing dispute relating to inter-company loan and management fees
The arbitration administrative court in Portugal recently ruled in favour of the taxpayer in a dispute with the Portuguese Tax Authorities (TA) in respect to the application of the arm’s length principle to inter-company loan and management fee
See MoreTreaty between Finland and Uruguay enters into force
The Income and Capital Tax Treaty between Finland and Uruguay entered into force on 6 February 2013. The treaty generally applies from 1 January 2014. The treaty is based generally on the model tax conventions of the OECD and UN. The definition of a
See MoreTreaty between US and Poland signed
United States has signed an Income Tax Treaty (2013) with Poland on 13 February 2013 which will replace the existing agreement, signed 1974. The new treaty provides for reductions in withholding taxes on cross-border payments of dividends,
See MoreNetherlands: New income tax allowances and tax rates for 2013 published
The 2013 income tax rates and allowances which apply at the BES Islands were published In the Official Gazette of 5 February 2013, Decree No. DB 20103-38M of 30 January 2013. For the year 2013 the tax rate for income from a substantial interest is
See MoreTax treaty signed between Germany and Oman
A double taxation treaty between Germany and Oman was signed in Muscat on 15 August 2012. This follows the conclusion of a bilateral investment promotion and protection treaty which was signed in 2010. The double taxation treaty generally follows
See MoreNew Tax fraud prevention Law enters into force in Spain
The new criminal code was introduced by Organic Law 7/2012, published in the Official Gazette on 28 December 2012. The code entered into force on 17 January 2013 with respect to transparency and fighting criminal tax and social security
See MoreGreece: New Transfer Pricing Documentation Rules
The Greek Parliament passed Income Tax amendments in January 2013 which changes to the transfer pricing provisions have been included. In Greece’s income tax law Article 39 and 39A have been repealed by new measures. According to the amendments
See MoreLatvia –Mexico: Treaty enter into force
The treaty between Latvia and Mexico for the avoidance of double taxation which was signed on 20 April 2012 is to enter into force on 2 March 2013. The maximum withholding tax on dividends is 10%, reduced to 5% where the recipient company is the
See MoreCroatia-Georgia:Double Tax Treaty signed
Croatia and Georgia signed a Double Taxation Agreement on January 18,
See MorePortugal: New withholding tax rates
The Official Gazette of Portugal published Order 796-B/2013 of the Ministry of Finance on 14 January 2013. Order 796-B/2013 approved the new withholding tax tables for personal income tax. The new withholding tax rates are applicable to employment
See MoreLithuania: Introduces new immovable Property Tax rates for 2013
Lithuanian new immovable property tax rates were introduced by the municipalities from 1 January 2013. The new rates vary from 0.3% to 3% of the taxable value of the property, whereas previously the immovable property tax rates were between 0.3% and
See MoreSlovakia: Amendments to the Income Tax Act
Slovakia's Parliament has passed legislation raising corporate and personal taxes from the beginning of 2013. The rate of corporate income tax would increase to 23% from 19%. Dividends paid out of profits generated before 1 January 2004 are subject
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