ITR Search | International Tax Review

Cyprus: Circular in Cyprus sheds light on transfer pricing adjustments

Anastasia Sagianni A circular issued by the Cypriot finance and tax authorities on November 24 2016 clarifies that they will also allow downwards or compensating transfer pricing (TP) adjustments.

February 28 2017

Understanding TP compliance for commencement tax returns

Companies beginning a new business venture in Nigeria face complex compliance rules on transfer pricing in the first three years. Victor Adegite and Adedayo Adebowale of KPMG Nigeria guide businesses through the possible hurdles.

February 28 2017

Georgia: Georgia and Liechtenstein DTA enters into force

Lopatina Irina Georgia has increased its portfolio of double taxation agreements (DTAs) to 54 countries after its treaty with Liechtenstein entered into force in late 2016.

February 28 2017

Poland: Poland overhauls structure of fiscal administration

Alicja Sarna Fiscal administration in Poland will face major changes in its structure and organisation from March 1 when the new law on National Fiscal Administration enters into force.

February 28 2017

Ireland: Moscovici in Ireland to discuss CCCTB

Catherine O’Meara Olivia Long EU Commissioner Pierre Moscovici appeared before the Irish Government Committee on Finance (the committee) on January 24 2017 to answer questions on the re-launch of the common consolidated corporate tax base (the CCCTB).

February 28 2017

South Africa: The spectre of withholding tax on service fees finally laid to rest

Sean Gilmour With effect from January 1 2017, proposed legislation relating to a possible South African withholding tax on service fees was formally deleted and a long period of uncertainty around this issue finally came to an end.

February 28 2017

Switzerland: Swiss voters reject Corporate Tax Reform III in its proposed form

Jacques Kistler Rene Zulauf In a referendum held on February 12 2017, the Swiss electorate voted to reject the Corporate Tax Reform III (CTR III), which had been approved by parliament.

February 28 2017

Russia: Russian MAP Profiles: A step forward in resolving treaty-related disputes

Alexander Grinko The BEPS Action 14 report "Making Dispute Resolution Mechanisms More Effective" (hereinafter, the 2015 Action 14 Report) contains a commitment by countries to implement a minimum standard to ensure that they resolve treaty-related disputes in a timely, effective and efficient manner by publishing their Mutual Agreement Procedure (MAP) profiles.

February 28 2017

Serbia: Serbia adopts amendments to VAT Law

Aleksandra Rafailovic The Serbian parliament adopted the Law on Amendments to the Law on VAT (Official Gazette of RS, No. 108/2016) on December 28 2016. The Law entered into force on January 1 2017 and the greatest impact of this Law will be felt by companies trading across borders.

February 28 2017

Hong Kong: Hong Kong plans new tax regime for aircraft leasing

Khoonming Ho Ayesha Macpherson Lau The Hong Kong government briefed the Legislative Council Panel on Economic Development on January 23 2017 about a proposed new tax regime for aircraft leasing in Hong Kong. This development comes at an opportune time when, for example, Boeing is forecasting global demand for 39,600 new airplanes over the next 20 years, with 38% for Asia-based airlines, of which 17% are for China.

February 28 2017

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