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Corporate Tax

15 February 2019
Elena Christodoulou Reference rates for notional interest deduction for 2019

Cyprus - Elias Neocleous & Co LLC

Article 9(B) of the Income Tax Law 2002 (as amended) provides for a notional interest deduction for tax purposes on new equity capital injected into companies and permanent establishments of foreign companies on or after 1 January 2015 to finance business assets, calculated by applying a reference rate to the new equity. The Tax Department recently announced the 10-year government bond yields for 31 December 2018, which will be used as the basis for the notional interest deduction for the 2019 tax year.

Author: Elena Christodoulou
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Pranay Bhatia Taxability of profit from sale of shares

India - BDO in India

While the classification of gains arising from a sale of shares has previously been litigated, the Bombay High Court recently dealt with the issue of whether gains arising from such a sale by a private trust would be taxable as capital gains or business income. The ruling examines not only the treatment of shares, but also the use of sales proceeds to conclusively adjudicate on the intentions behind the sale.

Author: Pranay Bhatia
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Varusha Moodaley One less issue when issuing tax invoices

South Africa - Cliffe Dekker Hofmeyr

A recent Value Added Tax Act amendment has created certainty regarding suppliers' ability to correct tax invoices that have already been issued and provides a remedy to recipient vendors which previously had difficulty obtaining a corrected tax invoice from suppliers. However, it remains unclear whether suppliers will be allowed to issue manual tax invoices reflecting the correct details where their systems do not allow for the issued tax invoice's particulars to be amended.

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

Switzerland - Walder Wyss

The Swiss Federal Tax Administration recently published the 2019 safe haven interest rates to be used on intra-group loans. Against this backdrop, this article provides an overview of the relevant Swiss tax rules associated with determining whether intra-group financing constitutes equity or debt for tax purposes and the consequences of each characterisation.

Authors: Maurus Winzap, Fabienne Limacher
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Recent updates

Pranay Bhatia Mumbai Tax Tribunal's recent rulings

India - BDO in India

Author: Pranay Bhatia
Constantinos Christofi New Cyprus-Saudi Arabia double tax agreement enters into force

Cyprus - Elias Neocleous & Co LLC

Author: Constantinos Christofi
Ralph E DeJong Top takeaways for tax-exempt employers from IRS guidance on executive compensation

USA - McDermott Will & Emery

Authors: Ralph E DeJong, Andrew C Liazos, Robert C Louthian III, Erika Mayshar
Simona Zangrandi VAT grouping provisions – an overview

Italy - Studio Legale Tributario Biscozzi Nobili

Authors: Simona Zangrandi, Franco Pozzi
Goh Ka Im Post-Budget 2019 – major amendments to Labuan Business Activity Tax Act

Malaysia - Shearn Delamore & Co

Authors: Goh Ka Im, Foong Pui Chi
Valery Narezhniy Price increases expected following VAT changes

Russia - Gorodissky & Partners

Author: Valery Narezhniy
Jerome Brink Important judgment for taxpayers regarding trading stock valuation

South Africa - Cliffe Dekker Hofmeyr

Author: Jerome Brink