France-Modification to capital gains tax regime
The President of France announced on 29 April 2013 that the tax regime on capital gains is to be modified. To encourage entrepreneurship the government will simplify the different existing regimes. Since 1 January 2013, occasional capital gains on
See MoreRussia: VAT treatment of agency services in connection with alienation of ERUs
The Russian Ministry of Finance has noted that the VAT treatment of services generally depends on the place of their supply. Recently they issued Letter No. 03-07-08/4775 on February 20, 2013 regarding the VAT treatment of agency services supplied
See MoreTreaty between Ireland and Ukraine signed
Ireland and Ukraine signed a Double Tax Agreement on 19 April 2013. This DTA represents an important step in boosting trade relations between Ireland and Ukraine. The treaty will enter into force when the relevant ratification procedures have been
See MoreNorway: Interest deduction limitation proposed
On 11 April 2013 the Norwegian Ministry of Finance published a legislative proposal and invited public submissions on the introduction of an interest deduction limitation for loans between related persons. The proposed limitation applies where there
See MoreIndia and Malta have signed a new Double Taxation Avoidance Agreement
India and Malta have signed a new Double Taxation Avoidance Agreement (DTAA) on April 8 2013. The provisions of the treaty generally follow the provisions of the OECD Model but the definition of a permanent establishment includes a building site or
See MoreTreaty between Albania and United Kingdom signed
On 26 March 2013, Albania and the United Kingdom signed a Double Taxation Agreement. The agreement generally follows the provisions of the OECD Model, with some modifications. The agreement will enter into force when the appropriate ratification
See MoreRussia: Clarifications regarding the advance pricing agreements
The Ministry of Finance has released Letter 03-01-18/2676 on February 6, 2013 clarifying the procedure for concluding advance pricing agreements (APAs) for foreign transactions. According to article 105.20 of the Tax Code the Ministry of Finance
See MoreUK: new double tax treaty with Norway
On 14 March 2013 the UK signed a new double taxation treaty with Norway. When the treaty enters into force it will replace the current treaty which was signed in 2000. The treaty generally follows the provisions of the OECD Model and incorporates
See MoreTreaty between Serbia and Vietnam signed
Serbia and Vietnam signed a Double Tax Treaty in Hanoi on 1 March
See MoreDraft list of commodities conditional to transfer pricing rules
Under the Russian transfer pricing (TP) rules in effect since 1 January 2012, import/export transactions with unrelated parties may be subject to the transfer pricing rules if such transactions involve global exchange-traded commodities. The
See MoreMalta and Norway DTA enters into force
A double tax agreement (DTA) between the Government of Malta and the Norwegian Government, signed on 30 March 2012, entered into force on 14 February 2013. New provision will come into application from 1 January, 2014 and these will replace the old
See MoreRussia: Amendments to Tax Code regarding corporate property tax
Russian Federal Law No. 202-FZ, issued on November 29, 2012, amended the Tax Code by introducing additional exemptions from corporate property tax. From January 1, 2013, the categories of assets not subject to corporate property tax include movable
See MoreCroatia-Georgia:Double Tax Treaty signed
Croatia and Georgia signed a Double Taxation Agreement on January 18,
See MoreTreaty between Liechtenstein and United Kingdom enters into force
The first Double Taxation Convention between the UK and Liechtenstein entered into force on 19 December 2012, which was signed in London on 11 June 2012. The Convention continues the cooperation between the UK and Liechtenstein on tax matters which
See MoreNew Swiss tax assistance law in effect
The Swiss Federal Council has announced that the new Tax Administrative Assistance Act (TAAA) will come into force on 1 February 2013. When the TAAA comes into effect the existing ordinance covering double taxation agreements will be repealed. The
See MoreMalta: Taxation of directors’ fees clarified
The tax authority of Malta clarifies the tax treatment of fees received by non-resident directors from companies resident in Malta. For this clarification, Malta tax authority has released a guidance note. Where the company is a resident, income
See MoreIncome and Capital Tax Treaty between Saudi Arabia and Ukraine
To build tax cooperation, Saudi Arabia and Ukraine signed an Income and Capital Tax Treaty on 2 September 2011 which enters into force on 1 December 2012. The treaty will be effective from 1 January 2013. According to the treaty the default tax
See MoreDouble Tax Agreement between Germany and Liechtenstein
Liechtenstein and Germany signed a bilateral double taxation agreement on 2011. The treaty will become effective from 1 January 2013. As per the agreement, there will be relief from withholding taxes for cross-border holdings as both countries
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