Ukraine: State Fiscal Service published letter regarding tax control over transfer pricing
The State Fiscal Service (SFS) published Letter No. 24525/7/99-99-22-01-02-17 issued on 7 July 2015 addressing the penalties levied for failure to submit transfer pricing (TP) documentation or to include relevant information about controlled
See MoreECJ: Advocate General’s opinion on whether units of a municipality can be taxable persons
The Advocate General of the European Court of Justice (ECJ) has delivered an opinion in the case of Gmina Wroclaw. The municipality of Wroclaw applied to the Polish Finance Minister on the issue of whether a budgetary unit of a municipality could be
See MoreUkraine: Cabinet of Ministers adopts new advance pricing agreement procedures
Ukraine’s Cabinet of Ministers published Resolution No. 504 on 25 July 2015 regarding conclusion of advance pricing agreements (“APA”) in respect of controlled transactions for transfer pricing purposes. The new Resolution replaces the former
See MoreDTA between Andorra and United Arab Emirates signed
A double taxation agreement (DTA) between Andorra and the United Arab Emirates was signed on 28th July
See MoreRussia: Input VAT deductibility on imported goods
The Finance Ministry has issued letter no. 03-07-15/31200 on 29th May 2015 to clarify the deductibility of VAT input tax on goods imported into Russia if the taxpayer has received a hard copy of the electronic customs declaration from the customs
See MoreDTA between Turkey and Senegal initialed
Following a successful second round of negotiations held from 8th July 2015 to 10th July 2015, a double taxation agreement (DTA) between Turkey and Senegal has been initialed in
See MoreIrish Revenue clarifies effect of ECJ decisions on VAT rules
On 17 July 2015 the Irish Revenue issued eBrief 73/15 outlining the practical implications of certain decisions of the European Court of Justice (ECJ) in value added tax (VAT) cases. The issues are related to VAT issues for pension funds. Supply of
See MoreDTA between Bulgaria and Norway ratified by Bulgaria
The Income Tax Treaty (2014) between Bulgaria and Norway has been ratified by the Bulgarian parliament on 8th July 2015. Once in force and effective, the new treaty will replace the previous income and capital tax treaty (1988). The ratification
See MoreRussia: Federal Council accepts amendments on CFC rules
The Russian Federation Council has accepted draft law, No. 714002-6 on 3rd June 2015 that contains changes to the Controlled Foreign Company (CFC) rules and the tax residency idea. It was signed by the President and officially published on 8th June
See MoreRussia: Convention on Mutual Administrative Assistance in Tax Matters enters into force
The Multilateral Convention on Mutual Administrative Assistance in Tax Matters has entered into force in regard to Russia on 1st July 2015. The Convention and the amending protocol apply to Russia from 1st January 2016. The agreement is intended
See MoreRussia: Corporate tax rate freeze
The Russian President has stated that tax rates will be frozen for the next four years and has indicated that he wants to encourage new and growing businesses. The Government also has a plan to announce investment incentives for existing
See MoreIceland Modifies Transfer Pricing Rules
Iceland's Parliament has approved a Bill on 15 June 2015 amending article 57 of the Icelandic Income Tax Act No. 90/2003 setting out transfer pricing rules. According to the Bill entities with turnover or total assets exceeding ISK 1 billion need
See MoreSwitzerland- Cyprus: Swiss parliament approves the treaty
The Swiss parliament approved the Cyprus - Switzerland Income and Capital Tax Treaty of 2014 on 19 June
See MoreHungary: Parliament approves tax laws for 2016
The Parliament of Hungary approved a package of previously announced tax law changes for 2016 on 16 June 2015. According to the approved Bill the personal income tax rate will reduce from 16% to 15%. The tax allowance for individuals raising two
See MoreHungary: Proposals for tax law changes for 2016 submitted to Parliament
The Government of Hungary recently submitted to the Parliament certain proposals concerning amendments to the tax law which will become effective from 2016. However certain changes regarding corporate income tax would take effect as from 2015. The
See MoreChina and Russia: DTA signed
The Double Tax Agreement (DTA) between China and Russia has been signed on 8th May
See MoreFATCA Agreement Signed between United States and Romania
Romania and the United States have signed a Foreign Account Tax Compliance Act (FATCA) agreement on 28 May 2015. This is a Model 1 Agreement. Under this reciprocal agreement, Romania will report the information required under FATCA about U.S.
See MoreRussia: Appeal Court agrees that payments made under a sham transaction are not tax deductible
The Appeal Court of Russia has ruled in Case no. А40-28065/13 on 25th February 2015 regarding fees paid for the use of know how. The fees are not deductible for corporate income tax purposes if the transaction is a fake. Summary of the case: LLC
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