ITR Search | International Tax Review

Russia: Russia’s APAs for cross-border transactions offer new possibilities

Alexander Grinko Since 2012, clause 2 of Article 105.20 of the Tax Code of the Russian Federation (the RF Tax Code) has allowed taxpayers to conclude advance pricing agreements (APAs) on cross-border transactions with related parties.

April 26 2017

Malta: Malta amends tax rules on qualifying employment in aviation

Mark Galea Salomone Donald Vella The Maltese legislator has continuously sought to attract high-net worth individuals and highly qualified individuals to Malta's shores, especially in the financial services, gaming and aviation industries.

April 26 2017

China: China finalises transfer pricing guidance

Khoonming Ho Lewis Lu Key clarifications were made to China's transfer pricing (TP) guidance recently. This included both the finalisation of guidance "localising" the OECD's BEPS TP work for China and clarifications on TP documentation and reporting requirements.

April 26 2017

Bulgaria: Clarifications published on dividends paid between Bulgaria and Moldova

Panayiotis Diallinas Moldova has recently clarified certain requirements relating to the taxation of dividends distributed during the period 2008-15 to residents of Bulgaria, in the context of the applicable double tax treaty concluded between the two countries in 1998.

April 26 2017

Australia: Multinational tax crackdown: Government update on tax audit activities in Australia

Melissa Lim On April 6 2017, the Australian Treasurer announced the progress made so far of the Australian Taxation Office's (ATO) multinational tax crackdown.

April 26 2017

Cyprus: Changes anticipated on acceptable profit margins between related companies

Maria Nicolaou Zoe Kokoni The Cyprus tax authorities, taking into consideration the international developments (OECD/G20 initiative – BEPS), have decided to amend the tax regime in relation to profit margins on loans between related parties.

April 26 2017

Hong Kong: New Hong Kong tax rules for aircraft leasing

Lewis Lu Curtis Ng On March 10 2017, the Hong Kong government gazetted the Inland Revenue (Amendment) (No.2) Bill 2017, which formally introduces a concessionary tax regime for certain aircraft leasing activities. The law was introduced into the Legislative Council for consideration and is expected to apply from the 2017/18 year of assessment. The main features of the proposed regime are:

April 26 2017

Albania: Albania changes Law on Hydrocarbons

Dorina Asllani Ndreka By adopting Law No. 6/2017, the Albanian Parliament amended the 1993 Law on Hydrocarbons (Exploration and Production). These latest changes are intended to make the law more easily applicable and to bring it closer to the acquis of the EU. The amendments also focus on safeguarding these important public assets.

April 26 2017

Spain: Unconstitutionality of municipal capital gains

The Spanish Constitutional Court (SCC) has reviewed the constitutionality of the different tax provisions at both national and foral region levels, regulating the tax on the increase in urban land value (IIVTNU).

April 26 2017

Planning it safe: Less risk and more substance

Tax planning is adapting to reflect a more transparent and technological world, bringing with it a change in attitudes and new challenges for taxpayers. The decisions made now should not be underestimated as they could have unexpected consequences later.

April 26 2017

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