Technical services fees under treaty between India and Germany
It was held by the Agra Bench of the Income-tax Appellate Tribunal of India that leather testing charges were taxable as “fees for technical services” under the India-Germany income tax treaty. The treaty allows the source state the right to tax
See MoreHungary Signs OECD Multilateral Tax Assistance Treaty
Hungary has become the 61st jurisdiction to sign the Organization for Economic Cooperation and Development’s multilateral treaty on multilateral tax assistance. This can be considered as a step of Hungary to its fight against cross-border tax
See MoreHungary- Amendments to Corporate Law
Hungary is going to modify its civil code by making significant changes to the corporate law which is likely to become effective from March 2014. According to the amendments, new companies may be permitted to establish their own company guidelines
See MoreRussia–Readjusting the taxable base for transfer pricing purposes may impact on the VAT base
The Russian Ministry of Finance has made public Letter No. 03-01-18/19214 clarifying the rights of tax authorities to readjust the taxable base in the case of selling goods and performing of works or services between related parties. Article 105.3
See MoreFinnish Administrative Supreme Court Order to pay interest on refunds of withholding tax collection
According to the Finnish Supreme Administrative court decision, Finland tax authority must pay interest on refunds of withholding tax collected in contrast to the EU law. The interest rate imposed on withholding tax refunds varies annually. In the
See MoreFrance and the US signed FATCA Intergovernmental Agreement
On 14 November 2013, the US and France signed an Intergovernmental Agreement (IGA), in order to improve international tax compliance and to implement the US Foreign Account Tax Compliance Act. The FATCA legislation aims to ensure that US citizens
See MoreEU: Planning to change the intrastate reporting process
The European Commission is plans to changes the Intrastate reporting process which is the month to month reporting procedure for EU VAT registered businesses. This enables the countries to follow the movement of goods in the free trade
See MoreECJ: Interest payable where VAT credit incorrectly refused
Recently, the European Court of Justice (ECJ) has ruled that member states may not lawfully withhold interest due on VAT credits or refunds. The ECJ held that EU member states cannot block VAT interest and has ruled that tax authorities still have
See MoreFrance – Arm’s length indemnification for unfair termination of contracts
In two court cases of France it was reported on 9 January 2013 that a failure to provide the required notice period with respect to a group restructuring may provide a cause of action for an award of compensation for unfair termination of a
See MoreFrance – 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
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