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Brazil’s Federal Revenue Attorney General’s Office issues formal opinion on remuneration of services rendered by foreign companies [TAX ALERT]

Brazil’s Federal Revenue Attorney General’s Office issues formal opinion on remuneration of services rendered by foreign companies [TAX ALERT]

March 11, 2014. Tags: , ,

The Brazilian Federal Revenue Attorney General’s Office (PGFN) recently published a formal Opinion, ratifying the Superior Court of Justice (STJ) decision that certain payments for …

EY Tax insght Slovakia’s new VAT filing obligations featured

Slovakia’s new VAT filing obligations

March 11, 2014. Tags: ,

Slovakian VAT payers must submit detailed VAT ledger reports under the country’s new filing obligation. We explore the implications for businesses.

France: two new tax measures to facilitate foreign and domestic investments

France: two new tax measures to facilitate foreign and domestic investments

March 10, 2014. Tags: , ,

On 28 February 2014, the Government announced a pair of tax simplification measures aimed at boosting investment, in particular from foreign companies. The first measure is …

FATCA agreement between India and United States – negotiations

FATCA agreement between India and United States – negotiations

March 10, 2014. Tags: , ,

Negotiations for an intergovernmental agreement to improve international tax compliance with respect to the US Foreign Account Tax Compliance Act (FATCA) between the United States …

Proposed treaty between US and Chile – US Joint Committee on Taxation issues report

Proposed treaty between US and Chile – US Joint Committee on Taxation issues report

March 10, 2014. Tags: , , ,

The Joint Committee on Taxation of the US Congress has released a summary of the proposed Chile–United States Income and Capital Tax Treaty (2010), signed …

Vietnam issues regulations on foreign contractor taxation [TAX ALERT]

Vietnam issues regulations on foreign contractor taxation [TAX ALERT]

March 10, 2014. Tags: ,

Foreign contractor taxes (FCT) apply to certain payments including interest, royalties, service fees, leases, insurance, transportation, transfers of securities and goods supplied in Vietnam or …

Progress of UK consultation regarding taxation of corporate debt and derivative contracts [TAX ALERT]

Progress of UK consultation regarding taxation of corporate debt and derivative contracts [TAX ALERT]

March 10, 2014. Tags: , ,

Update on working groups Draft clauses for inclusion in the UK Finance Bill 2014 which relate to changes to (i) the partnership rules in the loan …

Swiss Federal Tax Administration issues clarifications on taxation of Swiss principal companies [TAX ALERT]

Swiss Federal Tax Administration issues clarifications on taxation of Swiss principal companies [TAX ALERT]

March 10, 2014. Tags: , ,

The Swiss Federal Tax Administration (SFTA) is currently issuing instructions to the cantonal tax authorities on how to inform the companies concerned regarding the interpretation …

Netherlands: new decree on investment institutions gazetted

Netherlands: new decree on investment institutions gazetted

March 7, 2014. Tags: , , , ,

On 18 February 2014, Decree No. BLKB 2014/15M on investment institutions (fiscale beleggingsinstelling) was published in the Official Gazette No. 5544. This decree replaces Decree No. …

India: decision that Commissioner has no jurisdiction to direct the TPO to make adjustments to the transfer pricing order

India: decision that Commissioner has no jurisdiction to direct the TPO to make adjustments to the transfer pricing order

March 7, 2014. Tags: , ,

The Income Tax Appellate Tribunal (ITAT) delivered its decision on 20 December 2013 in the case of Tata Communications Ltd. vs. DCIT (ITA (TP) Nos.3121&3122/M/2013) …

Greece: APA guidelines issued

Greece: APA guidelines issued

March 7, 2014. Tags: , ,

It is reported that the Government issued Regulations on 31 December 2013 to provide guidance regarding the Advance Pricing Agreement (APA) program that is effective …

Swedish Supreme Administrative Court rules on the distinction between debt and equity for a convertible bond [TAX ALERT]

Swedish Supreme Administrative Court rules on the distinction between debt and equity for a convertible bond [TAX ALERT]

March 7, 2014. Tags: , , ,

The Swedish Supreme Administrative Court (the Court) issued a ruling on 14 February 2014, pertaining to the distinction between debt and equity – where it …

OECD updates schedule for stakeholder input in BEPS project [TAX ALERT]

OECD updates schedule for stakeholder input in BEPS project [TAX ALERT]

March 7, 2014. Tags: , ,

On 20 February 2014, the OECD released an updated timetable for its work on the areas of the Action Plan on Base Erosion and Profit …

UAE-Kazakhstan Income Tax Treaty enters into force [TAX ALERT]

UAE-Kazakhstan Income Tax Treaty enters into force [TAX ALERT]

March 7, 2014. Tags: , , , ,

The income tax treaty (the Treaty) between the United Arab Emirates (UAE) and the Republic of Kazakhstan which was signed on 22 December 2008 has …

European Union and United Kingdom: European Commission refers UK to CJEU over retroactive right to recover unlawfully collected tax – case number available

European Union and United Kingdom: European Commission refers UK to CJEU over retroactive right to recover unlawfully collected tax – case number available

March 6, 2014. Tags: , , ,

The number of the Court of Justice of the European Union (CJEU) in the case of Commission vs. United Kingdom (Case C-640/13) on discriminatory rules …

Croatia: reporting obligations introduced based on Savings Directive

Croatia: reporting obligations introduced based on Savings Directive

March 6, 2014. Tags: , ,

On 24 February 2014, the tax authority issued a notice on the obligation to report on interest payments, which is regulated by the provisions of …

Canada: draft legislation concerning taxation of Canadian banks with foreign affiliates

Canada: draft legislation concerning taxation of Canadian banks with foreign affiliates

March 6, 2014. Tags: , , , ,

On 27 February 2014, the Department of Finance released draft legislative proposals relating to the Canadian Income Tax Act and Income Tax Regulations concerning the …

India presents 2014-15 Interim Budget [TAX ALERT]

India presents 2014-15 Interim Budget [TAX ALERT]

March 6, 2014. Tags: , , ,

On 17 February 2014, India’s Finance Minister (FM) presented the Interim Budget for 2014-15 in the Parliament. This Tax Alert provides the key highlights of …

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