Category: Legislation
Canada: “Changing Of The GAAR”: A Background On The General Anti-Avoidance Rule, And Canada’s Attempt To Expand Its Tax Power In The 2022 Budget
The Budget purports to introduce several new financial and taxation regimes, as well as enhance several existing mechanisms. One of the existing taxation mechanisms proposed to be amended is the General Anti-Avoidance Rule (the "GAAR"). The Government initially indicated they would be amending the GAAR in the 2021 Budget. The 2022 Budget now provides some additional detail, though we are still waiting for the actual legislation. ... - Continue reading
Spain’s National Court challenges the deductibility of intragroup services in the absence of a written contract
In recent years, the Spanish tax administration and Spanish courts have had a clear tendency to challenge the provision of intragroup services, denying its corporate income tax deductibility and increasing the tax burden for taxpayers carrying out these transactions in Spain. ... - Continue reading
Canada: Taxpayers Must Pay Interest On Non-Existent Tax Debts
Following a transfer pricing audit, the Bank of Nova Scotia (BNS) entered into a settlement with the CRA on March 13, 2015, whereby certain amounts would be included in its income for the 2006 to 2014 taxation years. ... - Continue reading
Romania implements new rules for establishing tax residence
New Romanian legislation in force for foreign legal entities. ... - Continue reading
Report: Most exporters do little to prevent foreign bribery
An anti-corruption watchdog on Tuesday ranked the United States and United Kingdom as the largest exporters most active at enforcing rules meant to prohibit companies from paying bribes in foreign markets, but said many others are doing next to nothing. ... - Continue reading
Turkey: Amendments In Transfer Pricing General Communiqué
A few transfer pricing laws in Turkey have been amended as per the concerned General Communiqué. Here they are. ... - Continue reading