Russia – Controlled transaction is classified as transactions within individuals
The Russian Ministry of Finance (MoF) has issued Letter No.03-01-18/38106 on September 16, 2013 that explains whether transactions with individuals should be treated as controlled transactions for the purposes of transfer pricing regulations.
See MoreRussia-Applicable fields for applying thin capitalization rules
The Ministry of Finance has published Letter No. 03-08-05/23521 regarding the applicability of the thin capitalization rules to interest payments made by a Russian company on a loan granted by a Russian bank issued on June 21, 2013. For example, a
See MoreSwitzerland: Flat’s Tax support to SMEs
It was reported that SGV (Switzerland’s main trade association), represents small- and medium-sized enterprises (SMEs) in Switzerland, has accepted the decision of the Swiss Council of States to refuse the people’s initiative calling for an end
See MoreSwitzerland: Tax burden remain stable in 2014
According to a media report, the Swiss Federal Department of Finance has issued its tax exploitation index for 2014 on 10 December 2013; it disclosed that the average tax burden in Switzerland will remain same in 2014, compared to 2013. On average,
See MoreRussia- Court rules for establishing thin capitalization to a sister company loan
Russia’s Federal Arbitration Court of the North-West region has issued Ruling No. А52-4072/2012 on September 18, 2013 concerning the establishment by a sister company of thin capitalization rules to a loan issued. Russian court practice already
See MoreRussian President commands more tax intermission for LNG
Russian President has called for tax intermissions to be prolonged to more gas deposits that produce the Novatek-controlled liquefied natural gas program in the Yamal peninsula and it should also cover the neighboring Gydan peninsula. The tax
See MoreNorway – Amended 2014 budget to implement interest limitation rules
Norway’s new government on 8 November 2013 presented its “adjustments” to the 2014 budget. The proposal to limit interest deductions on related-party loans, for the most part, will move forward from the prior budget proposals and will be
See MoreMalta: Budget 2014
Malta’s Minister of Finance presented the government’s budget for 2014 on November 04, 2013. The 2014 budget holds various measures including expense findings for business visionaries who offer apprenticeship positions and work arrangements.
See MoreCanada-Serbia DTA enters into Force
The revenue agency declared that the Double Taxation Agreement (DTA) between Canada and Serbia has entered into force on October 31, 2013 and it was actually signed on April 27, 2012. On the basis of this agreement, a 5% tax withheld will be levied
See MoreNew DTA between Argentina and Switzerland
The governments of Argentina and Switzerland initialed a new double taxation agreement on 5 November 2013. The agreement will promote foreign investment and ensure legal certainty. If the final text of the agreement is approved by the two countries
See MoreA ‘FATCA’-type Agreement has been signed by Cayman and the UK
A bilateral governmental agreement has been signed by The Cayman Islands with the United Kingdom on November 05, 2013 which set the foundation for the automatic exchange of financial information about UK taxpayers who hold accounts in the Cayman
See MoreLuxembourg – Income tax treaty with Seychelles
The income and capital tax treaty between Seychelles and Luxembourg entered into force on August 19, 2013, and which will effective from beginning of January 2014. The Seychelles concluded one of the first treaty with Luxembourg. This treaty
See MoreTIEA between Argentina and Macedonia will enter into force
The government of Argentina and Macedonia signed a tax information exchange agreement on 26 April 2013. After completing necessary ratification procedures the agreement will enter into force on 17 December
See MoreIreland -Switzerland: Protocol tax treaty signed
The Protocol to the double tax agreement (DTA) initialed between Switzerland and Ireland will be effective in Ireland from January 1, 2014, which entered into force on November 14,
See MoreItaly and Switzerland closer to resolving tax disputes
A further round of bilateral negotiations was held between Italy and Switzerland in Rome which aimed at resolving important tax issues between the two countries. Italy and Switzerland agreed to find a solution to a number of major points of tax
See MoreTreaty between Malawi and Norway enters into force
The Malawi - Norway Income Tax Treaty (2009) entered into force on 10 December 2012. The treaty generally applies from 1 January 2013 for Norway and from 1 July 2013 for Malawi. From this date, the new treaty generally replaces the Malawi -
See MoreSwitzerland: Budget Surplus despite Revenue Dip
The Swiss Federal Department of Finance released that the Confederation is forecasting the excess budget of this year CHF0.3bn (USD0.33bn) on 1 November 2013. Switzerland’s budget presented for a shortage of CHF0.4bn in 2013. Revenues are expected
See MoreFor Far-East region Russia has sanctioned Federal Law
Russia’s President has signed Federal Law No. 267-FZ on September 30, 2013 to provide incentives for completing regional investment program within the Far East regions. In order to raise financing in the economy of the far-east region, the law
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