Russia: Law providing CFC rules signed
The President of Russia has signed a Federal Law No. 376-FZ for introducing the CFC rules on 24th November 2014. The law enters into force with effect from 1st January
See MoreThe Finance Ministry clarifies income allocation and expenses to Russian PE
The Finance Ministry (MoF) has published a Letter No. 52359 for describing the allocation of income and expenses to a Permanent Establishment (PE) in Russia of a non-resident company and it has issued on 17th October 2014. In accordance with article
See MoreHungary, Bahrain, Saudi Arabia and Jersey: Approval of TIEA
On 25th October 2014, the Hungarian parliament approved the pending income tax treaties with Bahrain and Saudi Arabia and a tax information exchange agreement with Jersey. On 24th February 2014, the tax treaty between Hungary and Bahrain was signed
See MoreDTA between Argentina and Switzerland approved by Argentine Chamber of Deputies
The Chamber of Deputies in Argentina last week approved the Income and Capital Tax Treaty between Argentina and Switzerland. The treaty concerns both income tax and capital gains, and it was signed in March 20, 2014. Furthermore it was already
See MoreRussia: President signs new tax monitoring law
The Russian President has signed the Federal Law No. 348-FZ on 4th November 2014 that enacts a new tax administration regime for large taxpayers in respect of the exchange of information between tax authorities and taxpayers. This tax monitoring
See MoreRussia: CFC law has been adopted by the Federal Council
The Federal Council has adopted the draft law on 19th November 2014 that initiates the CFC rules. There is no significant change in the adopted law compared to the previous draft. This law will enter into force with effect from 1st January
See MoreSwitzerland- China (People’s Rep.): Treaty enters into force
The China (People's Rep.) - Switzerland Income and Capital Tax Treaty of 2013 enters into force on 15 November and it will be applicable from 1 January 2015.The new treaty will replaces the China (People's Rep.) - Switzerland Income and Capital Tax
See MoreSwitzerland-Cyprus Treaty Approved By Swiss Federal Council
The Swiss Federal Council approved the Cyprus-Switzerland Double Tax Treaty on 12 November 2014 which was signed on 25 July 2014.The treaty will now be submitted to Parliament for
See MoreSwitzerland- Hungary: Treaty enters into force
The Hungary - Switzerland Income and Capital Tax Treaty of 2013 entered into force on 9 November 2014 and this new treaty will be applicable from 1 January 2015. This treaty will be replaces the Hungary - Switzerland Income and Capital Tax Treaty of
See MoreCyprus and Iceland sign Double Taxation Agreement
The Republic of Cyprus and the Government of Iceland signed a Double Taxation Avoidance Agreement, on 13 November 2014, concerning income and capital. The agreement is based on the OECD Model Convention. By signing this agreement both countries aim
See MoreFrance and Serbia Sign Social Security Agreement
France and Serbia signed a social security agreement on 6 November 2014. After in force and effective the agreement will be replaced by the France and former Serbia-Montenegro Social Security Agreement (1950) which was amended in 1967, 1974 and
See MoreEFTA and Bosnia-Herzegovina: FTA enters into force
The multilateral free trade agreement (FTA) between Bosnia and Herzegovina and EFTA (the European Free Trade Association) states- Iceland, Liechtenstein, Norway and Switzerland signed on 24 June 2013 and the agreement will enter into force for
See MoreRussian Parliament to Consider Revised Draft of CFC Law
On 22 October 2014 the Russian parliament received a new version of the draft law on controlled foreign companies (CFCs). Parliamentary hearings on the latest draft law are to take place on 11 November 2014. Generally the draft law aims to
See MoreChina signs new tax treaty and protocol with Russia
China signed a new income tax treaty and protocol with Russia on 13 October 2014. The key changes made in the new treaty are: In Article 4, “place of effective management” has been included as a one of the criteria for determining residency
See MoreDTA between Argentina and Switzerland approved by Argentina
The Argentine Senate approved the Income and Capital Tax Treaty between Argentina and Switzerland, on October 22, 2014 and it was signed in March 20, 2014. The treaty has now been submitted to the Chamber of Deputies for further
See MoreAustralia: new tax treaty with Switzerland enters into force on 14 October 2014
Australia-Switzerland new tax treaty has entered into force on 14 October 2014. The treaty, which was signed on 30 July 2013, replaces the existing Australia-Switzerland tax treaty which was signed in 1980. The new treaty will encourage further
See MoreCourt decides that the provision of tax treaties between Germany & Russia do not obstruct the application of thin capitalization rules
The Federal Arbitration Court of the Moscow decides that the provision of tax treaties between Germany & Russia do not obstruct the application of thin capitalization rules. The Federal Arbitration Court of the Moscow Circuit (FAC) decided in
See MoreChina signs a new tax treaty with Russia
China and Russia entered into a new double taxation treaty which was signed on October 13,
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