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Corporate Tax

12 April 2019
Tim Barrett Federal government tables 2019 Budget: investing in middle class

Canada - Thorsteinssons LLP

The minister of finance recently tabled the 2019 Budget. As a pre-election budget, the government appears to have shied away from tax measures that could receive negative backlash from the business community. Among other things, the government is proposing to expand the foreign affiliate dumping rules to apply to Canada-resident corporations that are controlled by non-resident individuals or trusts.

Author: Tim Barrett
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Pranay Bhatia Hedging loss is not international transaction

India - BDO LLP

In a recent case before the tax tribunal, a taxpayer gave an unsecured loan to its associated enterprises for which it had charged interest equal to LIBOR plus 250 basis points based on the rate at which it had borrowed funds from a foreign bank. The tax tribunal upheld the taxpayer's benchmarking and rejected the lower tax authority's contention that had the taxpayer advanced the loan to a third party, it would have charged a mark-up for its administrative expenses and the risk borne therein.

Author: Pranay Bhatia
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Louis Botha Domestic treasury management companies – alignment of tax and exchange control provisions

South Africa - Cliffe Dekker Hofmeyr

When the domestic treasury management company (DTMC) regime came into effect in 2013, a 'DTMC' was defined in the Income Tax Act as a company that is incorporated or deemed to be incorporated in South Africa. The 2019 Budget explains that in 2017 the Income Tax Act was amended to remove this requirement, which conflicts with the South African Reserve Bank's requirements, prompting calls for reassessment.

Author: Louis Botha
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Recent updates

Pranay Bhatia Transfer pricing adjustments must be restricted to international transactions and made at transactional level

India - BDO LLP

Author: Pranay Bhatia
Tsangadzaome Mukumba Controlled foreign company comparable tax threshold to be decreased

South Africa - Cliffe Dekker Hofmeyr

Author: Tsangadzaome Mukumba
Franco Pozzi Impact of Anti-tax Avoidance Directive on Italian CFC legislation

Italy - Studio Legale Tributario Biscozzi Nobili

Authors: Franco Pozzi, Fabrizia Orsillo
Elena Christodoulou Reference rates for notional interest deduction for 2019

Cyprus - Elias Neocleous & Co LLC

Author: Elena Christodoulou
Maurus Winzap Intra-group debt financing: updated safe haven rates and thin capitalisation rules

Switzerland - Walder Wyss

Authors: Maurus Winzap, Fabienne Limacher

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