Austria | Withholding tax on dividend distributions, capital gains: The withholding tax rate for dividends and capital gains will be increased to 27.5% (up from the current rate of 25%). If dividends are paid to corporations, a reduced withholding tax rate of 25% may still apply. It is expected the 25% rate would also apply to dividends paid to foreign corporations (but is subject to confirmation by the tax authorities). Interest payments on cash deposits and with respect to other loans involving banks (bank savings, transfer accounts) will continue to be subject to the 25% rate even if being paid to individuals. |
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United Kingdom | Corporate tax rate: According to the budget,the main rate of corporation tax, which applies to all companies subject to corporation tax except for those within the oil and gas ring fence, will be reduced to 19% from 1 April 2017 and 18% from 1 April 2020.The bill will be considered in a Public Bill Committee, expected to complete its work by 20 October 2015.
Dividend Tax: The current dividend tax credit is to be replaced by a GBP 5,000 tax free dividend allowance from April 2016. The new rates of dividend tax on income above the allowance are 7.5% for basic rate taxpayers; 32.5% for higher rate taxpayers and 38.1% for those on the additional rate. |
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Belgium | Withholding tax rate: The rate of withholding tax on movable income (interest, dividends) would increase from 25% to 27% (with no changes expected for the “classical” savings deposits). |
Tanzania | Corporate tax rate: The Budget 2015/16 was presented to the National Assembly by the Minister of Finance on 11 June 2015.Budget changes on which are given below: The presumptive tax rates (for businesses with an annual turnover of more than TZS 4 million but less than 7.5 million) are reduced by 25%. The Budget 2014/15 increased the rates: from 2% to 4% (now reduced to 3%) for companies with records; and from TZS 100,000 to TZS 200,000 (now reduced to TZS 150,000) for companies with incomplete records. |
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Romania | Withholding tax rate: The drafts of the revised Tax Code and Fiscal Procedures Code were approved by the Chamber of Deputies (deciding chamber) On 25 June 2015. A Proposal to reduce the withholding tax on dividends to 5% with effect from 1 January 2016 (instead of 0% as initially proposed). |
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Poland | Related party test: According to the revised second draft, the management or control shareholding of a taxpayer qualifying as a related party for transfer pricing purposes has been increased to 25% which was proposed as 20% in the first draft. |
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Russia | CFC Rules: The Russian Federation Council has accepted draft law, No. 714002-6 on 3rd June 2015 that contains following changes to the Controlled Foreign Company (CFC) rules:-New requirements for the determination of a controlling party of a foreign structure -Meaning of an active foreign holding company and -Meaning an active foreign sub-holding company. |
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Uganda | Thin capitalization rules: The tax deductible interest bearing debt to equity ratio in relation to foreign controlled entities in Uganda has been increased from 1:1 to 1:1.5. |
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Hungary | Surtax rate: The Government of Hungary recently submitted to the Parliament certain proposals concerning amendments to the tax law, which will become effective as from 2016. From 1 January 2016, the surtax rate for credit institutions will be 0.31% instead of 0.53% of the part of the tax base in excess of HUF 50 billion.With no modification to the surtax base, the ceiling of the surtax rate will be 0.21% instead of 0.31% in 2017 and 2018. The amount of surtax payable cannot exceed the total amount of bank tax paid (payable) in FY2015 for the period between 2016 and 2018. |
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World Tax Brief: June to July 2015
04 August, 2015