On 5 December 2012, the Appeal Court heard case No. ?40-60755/12-20-388 between the Russian branch of Eastern Value Partners Ltd. (EVP Co.), a company resident in Cyprus, and the tax authorities. The tax authorities denied the applicability of the Cyprus - Russia Income and Capital Tax Treaty (1998) on the grounds that the conditions regarding […]
On 25 January 2013, the Ministerial Decree of 11 January 2013 was published in the Official Gazette No. 21. The Decree amends article 1 of the Ministerial Decree of 4 September 1996 to include Iceland in the list of countries which fulfil the exchange of information requirements (the "white list"). The inclusion of Iceland derives […]
According to the Finance Law for 2013 (Loi de finances pour 2013, LF 2013), the cap for the overall amount of tax credits (under article 200-0 A of the French Tax Code) for 2013 is EUR 10.000. In 2012, the cap for the overall amount of tax credits was EUR 18.000 + 4% of the […]
On 14 January 2013, HM Revenue & Customs (HMRC) published new section INTM120085 of the International Manual on company residence, providing clarification on non-standard treaty tie-breaker rules. According to certain double taxation agreements, e.g. Canada - United Kingdom Income Tax Treaty (1978), Netherlands - United Kingdom Income Tax Treaty (2008) and United Kingdom - United […]
On 8 November 2012, the Ministry of Finance issued a letter No. 03-01-18/8-162 clarifying the tax treatment applicable to assets (works, services, or property rights) received free of charge in transactions between independent parties. The Ministry of Finance clarified that assets received free of charge from an independent entity should be reported by the beneficiary […]
