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Australia: Capital gains tax withholding

Eddie Ahn On February 25 2016, the draft legislation introducing a new foreign resident capital gains tax (CGT) withholding regime received Royal Assent after being passed by the Australian Parliament. These rules take effect from July 1 2016 and impose a withholding tax obligation on purchasers of certain Australian real estate related assets.

March 30 2016

Bosnia and Herzegovina: Instruction on indirect tax exemption under Instrument for Pre-Accession Assistance Programme II

Igor Vujasinovic On November 11 2015, a new Instruction issued by the director of the Indirect Tax Authority of Bosnia and Herzegovina entered into force. The Instruction was published in the Official Gazette of Bosnia and Herzegovina on November 30 2015.

March 30 2016

US Inbound: US Tax Court upholds IRS authority to make aggregated TP adjustments

Jim Fuller David Forst Guidant v Commissioner, 146 TC No 5 (2016) is a transfer pricing case addressing the IRS's ability to make a single adjustment for a US affiliated group where different US members of the group engaged in intercompany transactions and different types of transactions occurred. In the case, six related US entities variously engaged in sales, licensing and services transactions with a large number of foreign manufacturing and distribution affiliates.

March 30 2016

Georgia: Georgia to amend corporate tax rules

Anna Pushkaryova The Ministry of Finance of Georgia has recently initiated important changes in the system of corporate income taxation, particularly related to the moment of taxation itself.

March 30 2016

The Brockman brief: The (post-BEPS) tax function of tomorrow

The evolution of international taxation, driven by the OECD’s BEPS Actions, is eliciting new ways of thinking about the effective management of an internal tax function.

March 30 2016

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

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