Archive
Taiwan to implement CFC, place of effective management concepts [TAX ALERT]
May 24, 2013. Tags: CFC, income tax, Taiwan
On 1 April 2013, Taiwan’s Legislative Yuan passed the first review of the Income Tax Act (ITA) amendments by incorporating the following two anti-avoidance tax …
India: decision that benefit of tolerance margin prevails only if difference between actual and arm’s length price does not exceed tolerance limit
May 24, 2013. Tags: income tax, India
The Special Bench of Income Tax Appellate Tribunal (ITAT) issued its decision on 30 April 2013 in the case of IHG IT Services (India) Pvt. …
China: further detailed interpretation on beneficial ownership published
May 24, 2013. Tags: China, dividends, Hong Kong, tax administration
The State Administration of Taxation published an opinion letter on 12 April 2013 (Shui Zhong Han [2013] No. 165 providing guidance on the interpretation of …
Czech Republic: bill amending tax laws in connection with re-codification of private law – submitted to parliament
May 24, 2013. Tags: corporate tax, Czech Republic, dividends, income tax, individual tax
On 15 May 2013, the lower chamber of the Parliament approved, in the first reading, a bill introducing important changes to tax laws, in connection …
Spain establishes National Office for International Taxation [TAX ALERT]
May 23, 2013. Tags: advanced pricing agreement, international tax, Spain, tax audit, transfer pricing
In April 2013, the Spanish Government established the National Office for International Taxation (Oficina Nacional de Fiscalidad International “ONFI”) an élite force that will focus …
Norway proposes restrictions on related party interest expense deductions [TAX ALERT]
May 22, 2013. Tags: interest, Norway
On 11 April 2013, the Norwegian government published a consultation paper that would impose significant restrictions on the deduction of interest paid to related parties Further …
Slovenia ratifies tax treaty protocol with Switzerland [TAX ALERT]
May 22, 2013. Tags: double taxation, Slovenia, Switzerland, treaty
The Slovenian Parliament ratified the first protocol to the double taxation treaty (the Protocol) between Slovenia and Switzerland on 7 March 2013. As the Protocol was …
China: individual income tax treatment of conversion of reserves to share capital clarified
May 21, 2013. Tags: China, income tax, individual tax
The State Administration of Taxation issued an announcement on 7 May 2013 (Gong Gao [2013] No. 23) clarifying the tax treatment of conversion of reserves …
European Union: Ecofin Council conclusions on tax evasion and tax fraud published
May 21, 2013. Tags: European Union, tax evasion, tax fraud
On 14 May 2015, the Economic and Financial Affairs Council (Ecofin) published its conclusions on tax evasion and tax fraud. The most important details are …
Israel: cabinet adopts Budget for 2013–14
May 21, 2013. Tags: budget, income tax, Israel, VAT
On 14 May 2013, the cabinet adopted the Budget for 2013–14. The IBFD has received information that the following proposals have been approved: Increase of the corporate …
By 2030 two-thirds of global middle class will be in Asia-Pacific
May 21, 2013. Tags: Asia, China, Europe, Growth, India
By 2030, two-thirds of the global middle class will be residents of the Asia-Pacific region, while Europe’s share of this population will have dropped by 14% according to Ernst & Young’s Hitting the sweet spot report.
Mexico’s Supreme Court rules on treatment of capital losses [TAX ALERT]
May 21, 2013. Tags: capital, Mexico
A recent decision by the Mexican Supreme Court upheld the rules that limit the use of capital losses from the sale of shares to income …
Italy releases APA program Bulletin – second edition [TAX ALERT]
May 21, 2013. Tags: APA, Italy, transfer pricing
On 20 March 2013, Italy released the second Bulletin of its APA (Advanced Pricing Agreement) program. The most interesting development is the significant increase in pre-filing …
Israeli Supreme Court ruling opens door for certain post-importation amendments [TAX ALERT]
May 20, 2013. Tags: customs and trade, Israel
The Israeli Supreme Court rejected an appeal by the Israeli Tax Authorities (ITA) and allowed Holis Industries Ltd (Holis) to make post-importation classification amendments to …
France, Germany, Italy, Spain, and UK agree to pilot for multilateral exchange of tax information [TAX ALERT]
May 20, 2013. Tags: France, Germany, information-exchange, Italy, Spain, tax evasion, UK
On 9 April 2013, France, Germany, Italy, Spain, and the UK announced an agreement to develop and pilot a multilateral tax information exchange facility. Under the …
Finland revises tax law amendments regarding dividends [TAX ALERT]
May 17, 2013. Tags: dividends, Finland, tax law
The Finnish Government announced on 4 April 2013 revised amendments to the country’s tax law with respect to the previously announced dividend amendments. The revised amendments …
Brazilian government widens the scope of qualifying entities under presumed profit method [TAX ALERT]
May 17, 2013. Tags: Brazil, corporate tax, income tax
On 4 April 2013, the Brazilian government enacted Provisional Measure 612/2013, which extends the thresholds for companies to be eligible for the presumed profit method. A …
UK Chancellor of the Exchequer requests European finance ministers to agree to automatic exchange of tax information between countries
May 17, 2013. Tags: information-exchange, tax avoidance, tax evasion, United Kingdom
In a letter of 13 May 2013 to EU finance ministers, published on 14 May 2013, the UK Chancellor of the Exchequer has requested their …











