Russia publishes bilateral and multilateral APA Procedure
On 3 May 2018, Russia published Decree No. 60 on the Official Gazette, which approves the procedures for the conclusion of advance pricing agreements (APAs). The Russian Finance Ministry delegated the competent authority powers with respect to
See MoreJersey: Ministry of Treasury presents 2018 Budget to the States Assembly
The Minister for Treasury and Resources, Alan Maclean, has presented the Finance Budget Law 2018 and it will be effective from May 4, 2018. The Government had published the Draft Budget 2018 on October 3, 2017. The measures generally applicable as
See MoreSerbia: National Assembly ratifies the Multilateral Instrument (MLI)
On 19 April 2018, the National Assembly approved the law for the ratification of the multilateral convention to implement tax treaty related measures to prevent BEPS (MLI). The agreement will enable Serbia to implement international tax cooperation
See MoreUkraine issues a letter on refund of overpayment of income tax by non-resident entity
Recently State Fiscal Service released a personal tax consultation letter regarding the refund of tax incorrectly withheld on income derived from Ukraine sources by a non-resident entity. Generally a 15% standard withholding tax rate is applicable
See MoreThe Swiss Federal Council approves tax proposal 17
The Swiss Federal Council has adopted the dispatch on TP17 for the attention of the Federal Assembly on 21st March 2018. It wishes to quickly to improve matters for domestic and foreign companies with the proposal, also on the basis of international
See MoreRussia introduces VAT on B2B foreign digital services from 2019
From 1 January 2019, Russia will introduce new value added tax (VAT) rules with respect to business-to-business (B2B) supplies of e-services provided to Russian customers. Russia introduced VAT liabilities on offshore providers of electronic
See MoreUkraine extends the list of low-tax jurisdictions
The Cabinet of Ministers of Ukraine has expanded the list of "low-tax" jurisdictions from 65 to 80 countries, adding 17 countries (Morocco, the United Arab Emirates and 15 others) and deleting two countries (French Guiana and Lesotho). The list
See MoreRussia approves bilateral exchange agreements for CbC reports
The Government of the Russian Federation has published Decree No. 184 of 21 February 2018, which amends Decree No. 805 of 14 August 2014 on the conclusion of agreements for the exchange of information in tax matters. The changes include the
See MoreRussia clarifies the deduction of losses incurred by consolidated group
On 9 March 2018, the Ministry of Finance (MoF) clarified the deduction of losses incurred by consolidated group members. Accordingly, the MoF stated that, under article 278.1(1) of the Tax Code (TC), the tax base of a consolidated group of taxpayers
See MoreRussia: MOF clarifies the application of the 0% rate to dividends
In March 2018, the Ministry of Finance (MoF) clarified the application of the 0% (CIT) rate to dividends received by a company in reorganization. According to article 284(3.1) of the Tax Code, a tax rate of 0% is applied to dividends received by a
See MoreRussia: MoF clarification on application of thin capitalization rules in the context of tax treaties
Recently, the Ministry of Finance (MoF) issued a Guidance Letter (No. 03-03-06/1/87340) and clarified the application of domestic thin capitalization rules in the context of tax treaties. According to a statement by the MoF, interest paid by a
See MoreNorway: Government publishes new guidance on MAP
The Norwegian Government published detailed taxpayer guidance on the mutual agreement procedure (MAP) framework set out in Norway’s tax treaties on 7th February 2018. It is an instrument which shall ensure that states apply the tax treaties
See MoreUkraine: SFS publishes guidance letter on definition of related parties
On 5 February 2018, the State Fiscal Service (SFS) published Guidance Letter No. 204/6/99-99-15-02-02-15/IPK of 18 January 2018 clarifying definition of related parties regarding holding ownership of a director who owns the corporate
See MoreUkraine clarifies the definition of controlled transactions for transfer pricing purposes
On 19 January 2018, the State Fiscal Service (SFS) released Guidance Letter No. 119/6 / 99-99-15-02-02-15 / IPK of January 12, 2018, which defines the definition of controlled transactions for cross border transaction purposes. Under the amendments
See MoreSwitzerland: Federal Council set the parameters for the dispatch on tax proposal 17
The Swiss Federal Council announced that it has set the parameters for the dispatch on the country's tax reform proposal (tax proposal 17) on 31st January 2018. The Federal Council's parameters that will be contained in the dispatch on tax proposal
See MoreIceland: Parliament adopts increased withholding tax rates for 2018
The parliament has approved the Budget for 2018 and it has implemented an overall increase in withholding tax rates effective 1 January 2018 as follows: the standard rate of withholding tax on Icelandic interest, capital gains and dividend income
See MoreUAE: Cabinet approves DTA with Croatia
The Cabinet of United Arab Emirates has approved the income tax agreement on January 7, 2018, with Croatia for the avoidance of double taxation and the prevention of fiscal
See MoreUAE: Cabinet approves DTA with Moldova
The Cabinet of United Arab Emirates has approved the income tax agreement on January 7, 2018, with Moldova for the avoidance of double taxation and the prevention of fiscal
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