Israeli tax exemption on Makams and government bonds to be abolished

April 12, 2011. Tags: income tax, Israel, News

As part of the steps taken by the Bank of Israel and the Israeli Ministry of Finance to stop local currency appreciation, legislation aiming to cancel the …

Advance rulings issued on Indian company’s transfer of shares

April 11, 2011. Tags: double taxation, income tax, India, News

In two recent rulings, the Authority for Advance Rulings (AAR) ruled on the taxation of capital gains arising from the sale of an Indian company under India’s …

US: IRS issues twelfth annual APA report

April 8, 2011. Tags: News, transfer pricing, United States of America

The IRS issued the twelfth congressionally-mandated, annual Advance Pricing Agreement (APA) report on 29 March 2011, in Announcement 2011-22.1 The twelfth annual report provides an updated discussion …

Australia: Foreign source income rules – time for action on your foreign investments

April 7, 2011. Tags: Australia, international tax, News, tax risk

On Thursday 17 February 2011, Assistant Treasurer Bill Shorten released exposure draft legislation that will significantly impact Australian businesses and investors in relation to controlled and non-controlled foreign …

New proposed Ireland-Singapore income tax treaty moves forward

April 6, 2011. Tags: income tax, Ireland, News, Singapore

On 28 October 2010, Ireland and Singapore signed an income tax treaty and accompanying protocol (tax treaty). This is the first treaty concluded between the two countries. …

Luxembourg Holding Company Regime is excluded from Brazilian Privileged Tax Regime list

April 5, 2011. Tags: Brazil, Luxembourg, News

On 28 March 2011, Brazil’s Federal Revenue Department issued a new regulation (ADE RFB 03/2011) removing Luxembourg holding companies from the Brazilian list of privileged tax regimes. On …

US: IRS clarifies field guidance on potential impact of transfer pricing adjustments on Section 965 foreign earnings repatriations

April 4, 2011. Tags: News, transfer pricing, United States of America

In a Large Business and International (LB&I) Alert released 25 March 2011, the Internal Revenue Service (IRS or the Service) has clarified how examiners should make a …

Brazil increases tax on financial transactions

April 1, 2011. Tags: Brazil, Financial Services, News

The Brazilian government introduced Decree Nr. 7,456 on 28 March 2011 increasing the tax on financial transactions (Imposto sobre operacoes financeiras or IOF). Based on the new Decree, …

Transfer pricing tops list of tax issues for oil and gas executives

March 31, 2011. Tags: News, oil and gas, transfer pricing

China transfer pricing developments: New administrative systems for special tax adjustments

March 30, 2011. Tags: China, News, transfer pricing

On 23 February 2010 China’s State Administration of Taxation (SAT) released Guoshuihan [2010] No. 84, entitled “Notice of Briefing on Antitax Avoidance Work in 2009” (Circular 84). …

Customs self assessments coming to India

March 29, 2011. Tags: customs and trade, India, News

The Indian Finance Minister presented the Union Budget for 2011-12 on 28 February 2011, which included a variety of customs-related changes. One significant change, which importers …

Venezuela release new transfer pricing rules

March 28, 2011. Tags: News, transfer pricing, Venezuela

New Venezuelan transfer pricing rules address the determination of the arm’s length range using interquartile statistical method Administrative Order SNAT/2010/L0090, issued by the National Integrated Service of the Customs …

Canadian federal budget 2011: a low-tax plan for jobs and growth

March 25, 2011. Tags: budget, Canada, News

“We are focused on securing our economic recovery… [and] on improving the financial security of Canadian workers, seniors and families,” said Canadian federal Finance Minister Jim Flaherty, …

EFTA Surveillance Authority submits a reasoned opinion to Norway

March 24, 2011. Tags: European Union, News, Norway

Current exit taxation regimes deemed out of compliance with the antidiscrimination and free movement of capital provisions of the EEA agreement Current exit taxation regimes deemed out of …

Turkey welcomes new commercial code

March 23, 2011. Tags: News, tax policy, Turkey

The new Turkish Commercial Code No. 6102 (new Commercial Code) has been accepted by the Grand National Assembly and published in the Official Gazette on 14 February …

EU: Opinion of Advocate General in the infringement procedure against Austria regarding the tax deductibility of donations

March 22, 2011. Tags: Austria, European Union, News

On 8 March 2011, Advocate General (AG) Trstenjak delivered her Opinion in the infringement procedure against Austria concerning the tax deductibility of charitable donations. Whereas donations to certain Austrian charities …

India’s Union Budget 2011-2012 proposes annual reporting requirements for liaison offices

March 21, 2011. Tags: budget, India, international tax, News

The taxability of a liaison office has been a matter of debate especially due to the limited activities permitted to be conducted by a liaison office …

Belgian government proposes change to participation exemption regime, further enhancing portfolio investments held through Belgian holding companies

March 18, 2011. Tags: Belgium, European Union, News, tax policy, withholding tax

On 11 February 2011, the Belgian government introduced a new law proposal for which an urgent discussion in parliament was requested in accordance with the Belgian constitution. One …