Search results for

Balazs Bekes On July 9 2012, the Hungarian Parliament voted on the financial transaction tax, which will be introduced as of January 1 2013. The new tax will apply to financial service providers with a seat or a site in Hungary, to the postal accounting centre, and, in some cases, to the Hungarian National Bank. Money transfers, collections, payments initiated by way of the beneficiary, cash disbursements, cash transfers payments, redemptions of letters of credits and checks, and central bank deposits made for a time period of between one day and two weeks will be covered by the new transaction tax.

Elena Kostovska In late June 2012, an amended Law on Tax Procedure was adopted in the FYR Macedonian Parliament. The last time this Law was amended was in the middle of 2011 with certain changes regarding the appeal procedures. This latest set of changes was suggested by the Ministry of Finance in an attempt to clarify certain aspects related to the procedure of tax control that were previously ambiguous. With the amendments, it is now stipulated that the tax authorities can perform unannounced tax audits on the premises of the taxpayer without previous notice should they need to obtain certain information that may have been requested by a foreign tax authority.

Zeki Gündüz

Janne Juusela On July 6 2012, the Finnish Supreme Administrative Court (SAC) issued and published an advance ruling (KHO:2012:56) concerning back-and-forth stock trading. In the ruling, capital losses arising in consequence of trading of shares back and forth within a short period of time were considered non-deductible based on the general tax avoidance provision in Article 28 of the Finnish Act on Assessment Procedure. The SAC justified the application of the tax avoidance provision because the seller repurchased stocks corresponding to the ones sold immediately after the selling. Furthermore, another ground for the ruling was the substantial amount of the capital losses arisen in consequence of the trades compared to the actual profit potential in the back-and-forth stock trading. As the justifications mentioned above were fulfilled in the case at hand, the SAC considered that the capital losses arisen in consequence of the stock trades were not deductible from the seller's capital gains in accordance with Article 50 of the Finnish Income Tax Act.

Luis Viñuales

BT and GMAC’s victory in a landmark case at the UK’s Upper Tier Tax Tribunal earlier this month allowing them to claim VAT rebates on bad debts from 1973 to 1997, opens the door for many other companies to make claims of their own.

India‘s rules on advance pricing agreements (APA), which were published today, allow for the introduction of bilateral and multilateral APAs.

India’s Income Tax Appellate Tribunal Pune Bench (ITAT) recently decided a case concerning the tax deductibility of fees paid to portfolio managers, and if followed, the judgment could see the extension of deductions to other investment managers’ fees, advisers say.

A constant issue faced by multinational taxpayers is whether branches or subsidiaries are a more useful and flexible part of the corporate structure and in what circumstances it is appropriate to employ one over the other.

HM Revenue & Customs has collected more than £1 billion ($1.6 billion) in transfer pricing yield between March 2011 and 2012. Tax practitioners hope the high figure means more resources for the authority’s advance pricing agreements (APA) programme.