Russia: 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
See MoreDTA between UAE and Romania signed
The Income Tax Treaty between United Arab Emirates and Romania has been signed on 5th May 2015. When in force and effective the new treaty will replace the Romania and United Arab Emirates Income and Capital Tax Treaty
See MoreSpain: Council of Ministers approves Spain-Andorra income tax treaty
The Spanish Council of Ministers approved the the Andorra-Spain Income Tax Treaty (2015) on 30 April 2015. The treaty was signed on 8 January
See MoreBulgaria: National Revenue Agency issues 2015 manual on personal and corporate income tax
The National Revenue Agency (NRA) has issued the 2015 manual on corporate and personal income tax on 28th April 2015. The manual, inter alia, deals with the following matters: Taxation scope Tax returns Tax payments and Penalty
See MoreSlovak Republic: Proposed amendments to tax legislation
The Slovak Republic has proposed changes in the tax legislation including corporate income tax, personal income tax and value added tax. The amendments should come into force from 1st January 2016. The changes are summarized below: Corporate
See MoreDTA between Czech Republic and Iran signed
The Income Tax Treaty between Czech Republic and Iran has been signed on 30th April 2015. Future information of the treaty will be reported
See MoreRomania and Norway sign income tax treaty
A convention between Romania and the Kingdom of Norway was signed on 27 April, 2015, for the elimination of double taxation and the prevention of income tax evasion. The new treaty will replace the Norway - Romania Income and Capital Tax Treaty
See MoreDTA between Nigeria and Spain enters into force
The Income and Capital Tax Treaty between Nigeria and Spain will enter into force on 5th June
See MoreRomania and Albania sign social security agreement
Romania signed a social security agreement with Albania on 27 February 2015. No details are now
See MoreSwitzerland: Completes corporate tax reform III
The Swiss Federal Council issued its parameters for the dispatch on the Corporate Tax Reform III on 2 April 2015 and The Federal Department of Finance will arrange a dispatch on the new rules by June 2015. After it has been accepted by the Council,
See MoreRussia: Law concerning notification process of CFCs adopted
The parliament has approved Law No. 667946-6 on 27th March 2015 for extending the deadline of tax resident’s notification about the involvements held in controlled foreign companies (CFCs). The deadline for notification has been extended from 1st
See MoreSocial Security Agreement between Israel and Moldova negotiated
The negotiations of Social Security Agreement between Israel and Moldova were held on 24th March 2015 and it is wished to be signed
See MoreRussia: State Duma considers new draft law regarding thin capitalization rules
The Russian State Duma Council accepted the decision on 17th February 2015 to incorporate a new draft of Law No. 724609-6 on the introduction of changes to Article 269, Part 2 of the Tax Code regarding the meaning of controlled debt. The draft law
See MoreRussia: Application for participation exemption by a tax agent
The Finance Ministry (MoF) has issued Letter No. 03-03-06/1/885 on 19th January 2015 for describing the application of the participation exemption by a tax agent giving dividends to a Russian company. In accordance with article 284 (3) of the Tax
See MoreBelarus and the United States signed a Foreign Account Tax Compliance Act (FATCA) Agreement
Belarus and the United States signed a Foreign Account Tax Compliance Act (FATCA) Agreement on 20 March 2015 More specifically, Belarus and the United States signed a Model 1 Agreement. Under the agreement, Foreign Financial Institutions (FFIs) in
See MoreSwitzerland and EU Initial Agreement on Automatic Exchange of Information
It is reported that Switzerland and the EU initialed a draft agreement on the exchange of tax information on 19 March 2015. Under this agreement the account data of taxpayers would be collected from 1 January 2017. This data would include the name,
See MoreSwitzerland: Goes forward to Phase 2 of the global forum peer review
On 16 March 2015 the Global Forum on Transparency and Exchange of Information for Tax Purposes published a supplementary report to its Phase I Peer Review of Switzerland. The supplementary peer review report had been requested by Switzerland on the
See MoreDTA between Belarus and Malaysia initialed
Malaysia and Belarus initialed a tax treaty following successful negotiations held from 10 to 13 March 2015 in Malaysia. Once signed, in force and effective, the new treaty will replace the former USSR - Malaysia Income Tax Treaty
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