EU: European Commission presents Working Paper on Thin Capitalization Rules
The European Commission has recently published working paper N.42, entitled "Thin Capitalization Rules and Multinational Firm Capital Structure" This paper examines the impact of thin capitalization rules (that limit the tax deductibility of
See MoreDTA between Greece and San Marino entered into force
The San Marino government issued Decree No. 9, which ratifies the double taxation agreement with Greece, on 28 January 2014. The agreement entered into force on the same
See MoreCyprus: Five new double tax agreements in effect
Recently, Cyprus has put five new double tax agreements (DTAs) into effect, including a treaty with the Ukraine which includes beneficial treatment for real estate owned through a Cyprus holding company. The country’s DTA with Russia used to
See MoreBelgium explains 2014 Tax Audit Focus
The Belgian Tax Administration has declared the areas that will be the focus of its tax audits in 2014, to encourage taxpayers to correctly fulfill their tax obligations, and to increase voluntary tax compliance in Belgium. The aim is to increase
See MoreBelgian tax reform begin to emerge
In Belgium a consensus is arising that taxpayers should declare both their income from capital and income from labor in their income tax declaration. Advocates of this idea suggest that the income tax scale should be revised, to strengthen the
See MoreAustria: Research Institute Calls for Symbolic Cut in Taxes on Labor
The President of the Austrian Institute of Economic Research has urged the Government to launch its offensive on reducing the fiscal burden on labor in Austria as early as next year, starting with a symbolic first step. He proposed that the
See MoreAustria publishes revised draft bill amending tax acts
A revised draft bill of the 2014 Tax Amendment Act (Abgabenänderungsgesetz 2014; AbgÄG 2014) was forwarded to the Austrian Parliament on 29 January 2014. The revised draft bill modifies the initial draft bill with amendments to certain Austrian
See MoreGreece- Transfer Pricing Requirements regarding Financial Services and APA
The following requirements relative to financial services and Advance Pricing Agreement (APA) are described below: Financial Services: Financial services must follow the arm's length principle. It should also be noted that interest is deductible
See MoreUnited Kingdom – Tax compliance by suppliers under government contracts
The Cabinet Office has published a slightly revised version of the UK government’s procurement policy note, with measures to promote tax compliance. The note provides guidance on the government's policy on the use of the procurement process to
See MoreSlovenia – Constitutional Court Suspends Real Estate Tax
Slovenia's Constitutional Court has suspended property tax assessments. The tax imposes a charge based on property value of between 0.15 percent for occupied residences through to 0.5 percent for empty homes and 0.75 for commercial properties.
See MoreSlovakia – Reduced corporate income tax rate
Slovakia’s Parliament has reduced the corporate income tax rate from 23% to 22% with effect from 1 January 2014. The reduced corporate income tax rate is effective for tax periods beginning after 31 December 2013. This change affects both the
See MoreNetherlands – Dividend withholding tax when companies located in Curaçao
The Advocate General of the Court of Justice of the European Union (CJEU) issued an opinion in two joined cases that involve profit distributions made by Dutch companies to their parent companies that are residents of Curaçao. The opinion of the
See MoreNetherlands – Distinction between loan interest and dividend
The Netherlands Supreme Court (Hoge Raad) on 7 February 2014 issued two decisions affecting taxpayers. The first decision related to whether a payment would be regarded as interest on a loan or as a participation dividend paid on a share capital
See MoreBelgium: Transfer pricing audits process
Likely high-risk targets for audits are highly leveraged companies, those with large tax losses carried forward, and those with fluctuating profits. Belgium has increased the number of transfer pricing audits and expanded the team of transfer
See MoreUnited Kingdom – Proposals related to tax disputes and identifying scheme promoters
HM Revenue and Customs (HMRC) has issued consultation documents which include proposals for taxpayers to make accelerated payment of tax that is in dispute or subject to enquiry and for identifying “promoters” of tax avoidance schemes. The
See MoreUnited Kingdom – Councils to Retain Tax Revenues from Shale Gas Developments
On 13 January 2014, the UK Prime Minister announced that the local councils in the U.K. that approve shale gas developments will be able to retain 100 percent of business rates collected from local shale gas sites, doubling the current 50 percent
See MoreSpain extends latest deadline for cash accounting
The opportunity for Spanish companies to join the new cash reporting VAT scheme has been extend to 31 March 2014. The Spanish VAT cash accounting scheme was announced last year to help small businesses better manage their cash flows. It enables
See MoreNetherlands – Revised rules for employing foreign workers
A new law in the Netherlands (“Foreign Nationals Employment Act”), effective from 1 January 2014, concerns changes to the current labor market rules. The new law was followed by a re-write of the implementation rules. The law generally affects
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