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Canada: Tax Court of Canada: Foreign rectification orders not binding on CRA unless properly recognised by Canadian courts

Francois Auger Julia Qian Wang In Canadian Forest Navigation Co Ltd (CFN), the Tax Court of Canada (TCC) determined as a question of law that the Canada Revenue Agency (CRA) is not bound by foreign rectification orders and is not precluded from taking a position contrary to such orders.

March 30 2016

Poland: New TP regulations on the way

Magdalena Marciniak In recent months the focus on transfer pricing as an area of fiscal policy has intensified, and legislative changes are on the way. There is an increased interest in TP issues, fueled primarily by declining budget revenues from income tax and the recent increase in the number of income taxpayers.

March 30 2016

Bulgaria: Exchange of tax and financial information in Bulgaria

Petar Varbanov On February 12 2016, Bulgaria ratified the Convention on Mutual Administrative Assistance in Tax Matters, as amended by the 2010 protocol, by way of Decree No 21 published in the Official Gazette No 14 of 19 February 2016 as well as the OECD Automatic Exchange of Information Agreement (2014), by way of Decree No 22 published in the same issue of the Official Gazette.

March 30 2016

New Zealand: Implementation of the global standard on automatic exchange of information

Alex Mackenzie The New Zealand Inland Revenue Department has released an official issues paper 'Implementing the global standard on automatic exchange of information' (Issues Paper). The Issues Paper follows New Zealand's announcement on May 7 2014 of its commitment to implement the G20's Automatic Exchange of Information (AEOI) Standard.

March 30 2016

Chile: Voluntary income tax payment opportunity

Rodrigo Winter Loreto Pelegri Chile has an integrated tax system under which corporate income tax is fully creditable against final taxes such as surtax and additional withholding tax when a dividend or profit distribution occurs.

March 30 2016

EU: Member states agree to implement BEPS Action 13 CbCR by EU-wide Directive

Bob van der Made In the public session of the ECOFIN Council meeting of March 8 2016, the EU's 28 finance ministers reached political agreement on a Dutch EU Council Presidency draft compromise text on the EU Commission's draft Council Directive amending Directive 2011/16/EU as regards mandatory automatic exchange of information in the field of taxation (between EU tax administrations), also known as 'DAC4'.

March 30 2016

Cyprus: Treaty analysis: Cyprus – Ethiopia double tax agreement

Christiana Nicolaou Cyprus is continuing to develop its network of double taxation treaties (DTTs) through the signing of a new DTT with the Federal Democratic Republic of Ethiopia, on December 30 2015. The treaty is based on the OECD Model Convention for the Avoidance of Double Taxation on Income and on Capital, and it was published with the official Cyprus Government Gazette on January 18 2016.

March 30 2016

The existing tax treaty between Cyprus and Germany has been amended

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