Ukraine: Tax authorities defines the controlled transaction
Recently the Ukrainian tax authorities issued a Guidance Letter No. 14491/6/99-99-15-02-02-15 regarding transactions with related non-residents of Ukraine, and transactions with residents of low-tax jurisdictions and sales of goods through a
See MoreRussia: Notification of tax authorities concerning CFCs
The Finance Ministry (MoF) has issued a Letter No. 03-01-23/30779 on 27th May 2016 for clarifying the responsibility of taxpayers to notify the tax authorities about CFCs. On the basis of section 3.1 of article 23 of the Tax Code, taxpayers have to
See MoreEl Salvador: Financial statements need to be submitted electronically by large taxpayers
The tax authorities issued Circular DG-001/2016 on 13 June 2016, launching that large taxpayers must file their 2015 financial statements together with the notes and tax report electronically using digital Form F-457 through the Ministry of
See MoreIMF publishes working paper on aid and fiscal policy
On 9 June 2016 the IMF published on its website a paper entitled “What does aid do to fiscal policy? New evidence”. As foreign aid is an important source of funding for some developing countries it is important to look at how aid is allocated
See MoreRussia: Draft Order for approving CFC notification form published
According to the Russian Tax Code, individuals and companies are needed to notify the tax authority of controlled foreign companies (CFC) of which they are considered controlling persons. Note that, these companies and individuals are considered to
See MoreRussia: MoF clarifications regarding interim dividends
The Finance Ministry (MoF) has issued a letter No. 03-03-06/2/21011 on 13th April 2016 describing the tax treatment of interim dividends paid by a Russian company to its company shareholders in an amount exceeding the net profits of the company in
See MoreLiechtenstein: Government plans to increase minimum corporate income tax
Recently the Liechtenstein government approved a report providing an increase in the minimum corporate income tax from the current CHF 1,200 to CHF 1,800. The report has been submitted to parliament
See MoreFrance-public consultation launched on 1% add-back on dividends within tax-consolidated groups
The Tax Administration of France published on 11 May 2016 guidelines on the taxation of dividends distributed within tax-consolidated groups following changes brought by the Amending Finance Law 2015. For financial years commencing on or after 1
See MoreFrance- amortization base of 140% further extended by 1 year
The French Ministry of Finance and Public Accounts has declared that the tax measure letting companies to use an amortization base of 140% on certain industrial investments will be further extended by 1 year. Accordingly for investments in
See MoreGuernsey: The amended Statement released on taxation of banking businesses
The amended Statement of Practice C22 on taxation of banking businesses was released on 28 April 2016. The company standard rate of income tax on company profits is 0% but a 10% tax rate applies to certain banking profits. In particular, under the
See MoreUkraine: No due regarding tax penalties
The State Fiscal Service (SFS) has recently published on its official website clarifications concerning situations when tax penalties relating to the 2015 tax year are not due. According to the transitional provisions of the Tax Code, no tax
See MoreRussia: List of documents substantiating exemption of CFC profits
The Federal Tax Service (FTS) has published a Letter No. ED-3-13/1427 on 4th April 2016 for describing the time limits for submission to the tax authorities of notifications on controlled foreign companies (CFCs) and the necessary documents
See MoreRussia: Draft law on CbC reporting requirements issued for public consultation
The Russian Finance Ministry has issued a draft law regarding the introduction of country-by-country (CbC) reporting in Russia on 8 April 2016. The CbC reporting requirements would apply only to international groups whose aggregate revenue according
See MoreSwitzerland: Published draft legislation on country-by-country reporting
The Swiss Federal Council published draft law with respect to Country-by-Country reporting for consultation on 13 April 2016. The draft law is based on the recommendations contained in the OECD BEPS Action Plan 13 (“Transfer Pricing Documentation
See MorePortugal-Budget Law for 2016 implements country-by-country reporting requirements
The Portuguese Budget Law for 2016 has been approved on 16 March 2016. The approved Budget Law implements country-by-country reporting requirements. Country-by-Country (CbC) reporting requirement will be applicable for domestic entities with
See MoreIsle of Man extends deadline for online filing of income tax returns
The Treasury department of the Isle of Man issued a press release on April 07, 2016 announcing that the deadline for the online filing of corporate and individual income tax returns has been extended to 11 April 2016. Primarily, the returns had to
See MoreRussia: FTS clarifies tax treatment of dividends received by a foreign company
The Federal Tax Service (FTS) has issued a letter no. SD-4-3/2765 on 19th February 2016 for clarifying the tax treatment of dividends received by a foreign company which voluntarily chooses to be considered as a Russian tax resident. According to
See MoreEU Joint Transfer Pricing Forum Discusses Comparables in the EU
The meeting of the EU Joint Transfer Pricing Forum (EU JTPF) on 18 February 2016 considered some of the relevant issues concerning transfer pricing including joint audits in the EU and the use of pan-European comparables. Joint audits in the EU A
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