Archive: interest
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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 …
Netherlands: updated annex to decree on classification of foreign entities published
May 8, 2013. Tags: foreign entities, interest, The Netherlands
On 14 April 2013, the Dutch tax administration published an updated annex to Decree No. CPP/2009/519M of 11 December 2009, on the classification of foreign …
Belgium and European Union: preliminary ruling requested on higher taxation of interest paid by non-resident banks
May 3, 2013. Tags: Belgium, European Union, Financial Services, interest
On 28 February 2013, reference was made to the Court of Justice of the European Union (CJEU) by the Belgium Constitutional Court (Court Constitutionelle) in …
Belgium: abolition of Belgian bank secrecy compatible with Belgian Constitution
April 30, 2013. Tags: Belgium, dividends, Financial Services, income, interest
On 18 April 2013, the Belgian Constitutional Court (Cour Constitutionelle/Grondwettelijk Hof) gave its decision on the petition of the vzw Liga van Belastingplichtigen of 11 …
Colombian Tax Authority confirms interest may be attributed to permanent establishments [TAX ALERT]
April 23, 2013. Tags: Colombia, interest, permanent establishment
In response to a request from Ernst & Young Colombia, related to Concept 079443 issued on 20 December 2012, the Colombian Tax Authority confirmed that …
Netherlands: decree on non-deductible interest published
April 10, 2013. Tags: corporate tax, income tax, interest, The Netherlands
In the Official Gazette of 3 April 2013, a decree of 25 March 2013 (BLKB2013/110M) on the non-deductibility of certain interest expenses was published (the …
Russia and Spain: treaty clarifies tax treatment applicable to interest payments
April 2, 2013. Tags: capital tax, income tax, interest, Russia, Spain
Recently, the Russian Ministry of Finance issued Letter 03-08-05/6369, clarifying the tax treatment applicable to interest payments based on the Russia–Spain Income and Capital Tax …
Russia: clarifications on deductibility of interest expenses related to loans taken to acquire shares
March 28, 2013. Tags: interest, Luxembourg, Russia, tax code
On 27 February 2013, the Ministry of Finance issued Letter No. 03-08-05/5690 clarifying the tax treatment applicable to interest paid on loans taken for the …
Switzerland: Federal Tax Administration announces safe haven interest rates for 2013
March 4, 2013. Tags: interest, Switzerland, tax administration, tax havens
On 25 February 2013, the Federal Tax Administration published two circulars and announced the safe haven interest rates applicable to shareholder and related party loans. Circular …
Belgium: European Commission request to amend taxation of paid interest
February 27, 2013. Tags: Belgium, CJEU, European Commission, interest
On 21 February 2013, the European Commission announced that it had sent Belgium a reasoned opinion (second stage of the infringement procedure under article 258 …
Netherlands joins the interest limitation trend
February 21, 2013. Tags: corporate tax, interest, tax benefits, The Netherlands
In an effort to raise revenue, decrease the deficit and repair any “mismatching” of the Dutch tax benefit system, the proposal for fiscal year 2013 proposes important changes.
European Commission proposes adaptation of tax directives for upcoming accession of Croatia
February 20, 2013. Tags: Croatia, European Commission, interest, royalties, tax exemption
On 8 February 2013, the European Commission sent a proposal to the Council for a directive adapting all directives in the field of taxation that …
Brazil: Federal Tax Authority issues ruling regarding treatment of interest on overpaid taxes
February 13, 2013. Tags: Brazil, corporate tax, income tax, interest, social security
On 29 January 2013, the Federal Tax Authority (Receita Federal do Brasil, RFB) issued Ruling No. 10/2013 (Solução de Consulta No. 10-2013, published in the …
Brazil: transfer pricing provisions – amendments to interest payments regulations
January 30, 2013. Tags: Brazil, interest, transfer pricing
Normative Instruction 1,322 (Instrução Normativa 1,322/2012), issued by the Federal Revenue Office and published in the Official Gazette of 18 January 2013, amends the transfer …
Congo: new tax measures enacted
January 29, 2013. Tags: Congo, direct tax, income tax, indirect tax, interest, Mining & Metals, tax law, VAT
The Democratic Republic of Congo (DRC) recently introduced major changes to its tax legislation through a series of ordinance laws enacted by the President. The main …
Bad loans and regulation will squeeze Eurozone banks in 2013
January 28, 2013. Tags: Eurozone, Financial Services, Insurance, interest
While the economic forecast for the Eurozone in 2013 shows painful progress towards stability, Eurozone banks and insurers will face another difficult year.
Brazil amends transfer pricing rules: New rules for deductibility of intercompany interest and new normative instruction [TAX ALERT]
January 22, 2013. Tags: Brazil, interest, transfer pricing
On 28 December 2012 the Law 12.766/12 introduced further changes to the recently enacted changes to the Brazilian transfer pricing rules for interest paid to …
Sweden’s drive for tax competitiveness
January 17, 2013. Tags: corporate tax, income tax, interest, OECD, Sweden, withholding tax
Sweden recently unveiled some tax proposals that reflect a significant reduction in headline corporate income tax rates (from 26.3% to 22%, effective 1 January 2013). Learn more.
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