ITR Search | International Tax Review

Practical treatment of transfer pricing adjustments

In the eighth in a series of articles on intangibles and finance, Philip de Homont and Alexander Voegele, NERA Frankfurt, show how to handle transfer pricing adjustments.

May 26 2016

Deals of the month

See who has done the tax work on this month’s biggest deals

May 26 2016

Special features - June 2016

Read this month's special features on Mexico and Intangibles

May 26 2016

Bosnia & Herzegovina: Federation of Bosnia & Herzegovina amends profit tax law

Igor Vujasinovic The Official Gazette of the Federation of Bosnia & Herzegovina (FBIH), no. 15/16 as published on February 26 2016 included the new profit tax law applicable in FBIH. The law entered into force eight days after its publication.

May 26 2016

FYR Macedonia: FYR Macedonia ratifies double tax treaty with UAE

Elena Kostovska On April 1 2016, the FYR Macedonian parliament ratified the tax treaty signed with the UAE on October 26 2015. The ratification law was published in the Official Gazette No 63 of April 1 2016.

May 26 2016

Chile: Chile extends corporate income tax credit use

Lorenzo Gálmez Paula Silva While the 2014 Tax Reform Act, N° 20.780, limited the full use of corporate income tax credit (known in Chile as First Category Tax Credit) to foreign taxpayers who were tax residents of countries with which Chile had double tax treaties (DTT) already in force, the "Simplification" Tax Reform Act, N° 20.899 of 2016, extended such benefit to residents of countries with which Chile has signed a DTT even if they are not yet in force, though same conditions.

May 26 2016

Australia: Australian Budget increases heat on cross-border taxpayers and transactions

Jock McCormack The Australian Government continued attacking multinational tax avoidance with its 2016-2017 Federal Budget released on May 3 2016. The announced measures include a 40% diverted profits tax on large multinationals from July 1 2017, akin to the UK diverted profits tax.

May 26 2016

Norway: Interest limitation rules restrict freedom of establishment, ESA states

Trond Eivind Johnsen "Norway has failed to fulfil its obligations arising from Article 31 of the EEA Agreement", states the EFTA Surveillance Authority (ESA) in a letter of formal notice to the Norwegian Ministry of Finance dated May 4 2016. The reason is Norway's interest limitation rules combined with the group relief rules

May 26 2016

Germany: Fiscal Court rules substance requirements under Cadbury-Schweppes exception to CFC taxation

Alexander Linn Thorsten Braun Germany's controlled foreign corporation (CFC) rules apply to CFCs earning passive income that is taxed at a rate of less than 25%. However, the rules do not apply to subsidiaries located in the EU/EEA if the Germany taxpayer can demonstrate that the subsidiary carries on a genuine economic activity in its state of residence (Cadbury-Schweppes exception, see ECJ, C-196/04). There is scant case law on what constitutes a genuine economic activity for these purposes.

May 26 2016

Revised India-Mauritius treaty ends decade-long tax debate

The protocol to amend the India-Mauritius tax treaty has been enacted. What can investors expect?

Amelia Schwanke, May 26 2016

Search results for