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Worldwide Tax News

Approved Changes (3)

Mexico

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Mexico Pushes Back Deadline for First Mandatory Filing of Electronic Accounting Records

On 27 February 2015, the Mexican Tax Administration Service (SAT) published a press release announcing that the deadline for the first mandatory filing of electronic accounting records through the tax administration portal has been pushed back to 3 April 2015. The first filing includes the initial chart of accounts and the monthly trial balance for January 2015. The same deadline applies for the February 2015 trial balance.

The electronic filing requirements were introduced with Mexico's 2014 tax reform, and include an initial submissions of the chart of accounts and the submissions of monthly trial balances. Aside from the delayed filing for January 2015, monthly trial balances should be submitted by the third day of the second month following each month, while subsequent submissions of the chart of accounts is required only when there are changes.  Taxpayers are also required to submit additional information electronically if requested by the tax authorities, such as vouchers and subsidiary ledgers.

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Peru Adopts new R&D Tax Incentive

The Peruvian Congress has recently adopted new tax incentives for scientific research, development, and technological innovation. With the new incentives, Peru-based taxpayers incurring expenses for such activities will be allowed a 175% deduction for projects directly developed by them or through a Peru-based research centers. When projects are developed jointly with foreign-based research centers, the deduction is reduced to 150%.

Prior to the implementation of the incentive, expenses incurred for scientific research, development, and technological innovation are 100% deductible.

Serbia

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Serbia Publishes Draft Arm's Length Interest Rates for Related Party Loans

On 27 February 2015, the Serbian Ministry of Finance published the draft rulebook containing the arm's length interest rates for related party loans. The rates apply for related party financing in 2014 regardless of the year the financing was granted. The rates, which vary by taxpayer type, loan type, and the denomination of the loan, are summarized as follows:

For banks and leasing companies: all loans

  • RSD denominated loans - 7.14%
  • EUR denominated loans - 4.39%
  • USD denominated loans - 3.12%
  • CHF denominated loans - 5.86%

For other companies: short-term loans

  • RSD denominated loans - 13.82%
  • EUR denominated loans - 6.57%
  • USD denominated loans - 5.28%
  • CHF denominated loans - 8.49%

For other companies: long-term loans

  • RSD denominated loans - 11.12%
  • EUR denominated loans - 5.79%
  • USD denominated loans - 5.74%
  • CHF denominated loans - 7.07%

For transfer pricing documentation purposes, taxpayers may elect to use the rates prescribed by the Ministry of Finance or apply other methods for determining the arm’s length rate. Once the election is made, the method chosen must be applied consistently to all loans to or from related parties.

Proposed Changes (1)

Switzerland

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Proposed Amendments to Swiss VAT Act will Result in Greater Taxation of Nonresident Suppliers

The Swiss Federal Council has approved draft legislation amending the country's VAT Act that will result in greater VAT liability for non-resident suppliers. The main changes affecting non-residents include:

  • The CHF 100,000 VAT registration threshold would be based on worldwide sales instead of just Swiss sales, and
  • The general exemption from import VAT for small deliveries with a VAT amount of CHF 5 or less would no longer apply

The amending legislation has been submitted to parliament for approval.

Treaty Changes (4)

Albania-Romania

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SSA between Albania and Romania Signed

On 27 February 2015, officials from Albania and Romania signed a social security agreement. The agreement is the first of its kind between the two countries, and will enter into force after the ratification instruments are exchanged.

Andorra-Belgium

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TIEA between Andorra and Belgium has Entered into Force

The tax information exchange agreement between Andorra and Belgium entered into force on 13 January 2015. The agreement, signed 23 October 2009, is the first of its kind between the two countries and is in line with the OECD standard for information exchange. The agreement applies for criminal tax matters from the date of its entry into force, and for other matters from 1 January 2016.

A protocol to the agreement, signed the same date, states that a full tax treaty will be negotiated after Andorra has introduced a tax on the profits of companies. A corporate income tax was introduced in Andorra in 2012.

Australia-Switzerland

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Australia and Switzerland Sign Joint Declaration on Automatic Exchange of Information

On 3 March 2015, officials from Australia and Switzerland signed a joint declaration on automatic exchange of information (AEOI). The declaration sets out the commitment to implement legislation that will allow for the automatic exchange of financial account data between the two countries beginning in 2018.

The declaration is the first of its kind between the two countries, and is in line with the OECD AEOI common reporting standard, which was released in July 2014 and has been endorsed by over 90 countries.

Barbados-Cyprus

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Tax Treaty between Barbados and Cyprus to be Negotiated

On 27 February 2015, it was announced that officials from Barbados and Cyprus have agreed to enter into negotiations for an income tax treaty. Any resulting treaty will be the first of its kind between the two countries, and must be finalized, signed and ratified before entering into force.

Additional details will be published once available.

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