KPMG's Week in Tax: 21-25 September

KPMG's Week in Tax: 21-25 September

Among the tax developments reported this week by KPMG member firms from around the globe are the following items:

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  • Denmark: The Danish government issued a legislative proposal that would provide measures to enhance the Danish transfer pricing documentation requirements and to include country-by-country (CbC) reporting. 
  • Korea: The high court in Seoul, reversing a lower court decision, held that a Korean entity was not liable for additional customs duty on international marketing fees paid to its corporate international headquarters. 
  • Italy: A legislative decree includes provisions intended to encourage foreign investment in Italy. Among the provisions are measures that allow multinational entities to enter into a five-year binding agreement with the Italian tax authorities for certain cross-border tax issues including transfer pricing. 

Read more at TaxNewsFlash-Transfer Pricing


  • Austria: Tax reform in Austria includes a provision to increase the rate of withholding tax that applies for dividend distributions made to non-resident companies.  
  • Luxembourg: A reminder is provided of the deadlines for taxpayers seeking to apply the functional currency regime, fiscal unity, and for determining the corporate net wealth tax. 
  • Russia: A procedure is established for entering into special investment contracts in certain industries. 
  • Serbia: A bill to amend the value added tax (VAT) law has been sent to the Parliament for its consideration.  
  • Spain: The standard rate of withholding tax on Spanish securities (debt securities and equities) has been reduced from the current rate of 20% to 19.5%. In relation to this, the Luxembourg tax authorities announced that application of the reduced rate under the income tax treaty between Spain and Luxembourg would not be available for certain identified Luxembourg investment vehicles.

Read more at TaxNewsFlash-Europe


  • Curaçao: The Lower House in the Netherlands approved a new arrangement for the avoidance of double taxation between the Netherlands—including its Caribbean territories—and Curaçao. 
  • Panama: The second installment of advance payments of estimated corporate income tax, for those corporate taxpayers with a 31 December year-end is due 30 September 2015.

Read more at TaxNewsFlash-Americas


  • China: Several Chinese agencies jointly issued guidance that suspends individual income taxation with respect to dividends distributed to "long-term individual investors" who obtained shares in listed companies by means of public offerings and market transfers and who have held the shares for a period of more than one year. 
  • China: The China Insurance Regulatory Commission (CIRC) introduced a pilot program in certain municipalities that provide preferential individual income tax treatment for certain health insurance products. 

Read more at TaxNewsFlash-Asia Pacific

FATCA developments

  • US: The United States has signed the first Competent Authority arrangements (CAA) with the United Kingdom and Australia—two jurisdictions with which the United States has entered into intergovernmental agreements (IGAs) to implement the FATCA regime.
  • Mauritius: The Mauritius Revenue Authority is accepting late FATCA reporting, if approved first, up to 30 September 2015 with no penalties to apply.   
  • Mexico: The Executive Branch’s economic package includes proposals to require financial institutions to comply with the rules for automatic exchange of information (AEoI) and the Common Reporting Standard (CRS). 
  • UK: HM Revenue & Customs published a new version of guidance notes for implementing the FATCA regime for the UK crown dependencies and overseas territories reporting regimes.

Read more at TaxNewsFlash-FATCA

United States

  • North Carolina: The governor on September 18, 2015, signed House Bill 97—the long-delayed budget bill—that includes tax reform measures affecting business taxpayers. 
  • Insurance: The U.S. Tax Court issued an opinion concluding that “residual value insurance”—a contract that insures against the risk that the residual value of an asset, when returned at the end of a lease, will be significantly lower than the expected value—as sold by the taxpayer constituted contracts of “insurance” for federal income tax purposes. 

Read more at TaxNewsFlash-United States


Read these and other items reported this week at the TaxNewsFlash United States and Global websites.

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