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Approved Changes (6)


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Belgium Individual Income Tax Brackets for 2015

The Belgian individual income tax bracket thresholds are all increased for 2015, although the tax rates for each bracket remain the same. The brackets and rates are as follows:

  • up to €8,710 - 25%
  • over €8,710 up to 12,400 - 30%
  • over €12,400 up to 20,660 - 40%
  • over €20,660 up to 37,870 - 45%
  • over €37,870 - 50%

In addition to the bracket threshold increases, the various personal allowances that apply in determining tax payable are generally increased for 2015 as well.


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Russia Clarifies Treatment of Loss Carryforwards When becoming Part of a Consolidated Tax Group

The Russian Ministry of Finance recently issued a guidance letter from 2014 which clarifies the treatment of loss carryforwards when a company becomes a member of a consolidate tax group directly or as the result of a merger. The key points of the letter are summarized as follows:

When a company become a member of a consolidated group, any net operating losses carried forward from periods prior to becoming a member of the group may not be utilized to reduce the group's tax base. The same restriction applies when a company becomes part of a group through a merger with an existing group member.

When a company ceases to be a member of a group, the losses carried forward from periods prior to becoming a group member may then be utilized and the loss carry forward limit of 10 years is extended for such losses by the number of years such company was a group member. The same applies to the losses of a merged company when the group member with which it was merged leaves the group.


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Singapore Publishes Revised R&D Tax Measures Guide (Fourth Edition)

On 22 January 2015, the Inland Revenue Authority of Singapore published the revised e-Tax Guide: Research and Development Tax Measures (Fourth edition).

The guide covers:

  • Conditions for Qualifying R&D Projects,
  • R&D tax deductions and capital allowances eligibility and application, and
  • Administrative procedures

The change in the fourth edition is the addition of Annex H, which covers how Singapore R&D incentives apply in regard to R&D in the Food and Beverage industry, including examples.

Click the following link for the Research and Development Tax Measures (Fourth edition).

South Africa

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Increased South African Withholding Tax on Interest and Royalties in 2015

South Africa has increased the withholding tax rates on interest and royalty payments in 2015. The rate for interest is increased from 0% to 15%, effective 1 March 2015. The rate for royalties is increased from 12% to 15%, effective 1 January 2015.

Payments to residents in jurisdictions with which South Africa has entered into an income tax treaty may be eligible for lower rates or exemption subject to certain conditions.


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New Top Individual Income Tax Rate and Bracket Applies in Taiwan in 2015

From 1 January 2015, a new individual income tax top bracket and rate of 45% applies in Taiwan. The new bracket is addition to the five brackets applicable in previous years, which remain the same. For 2015 the brackets and rates are as follows for resident taxpayers:

  • up to TWD 520,000 - 5%
  • over TWD 520,000 up to 1,170,000 - 12%
  • over TWD 1,170,000 up to 2,350,000 - 20%
  • over TWD 2,350,000 up to  4,400,000 - 30%
  • over TWD 4,400,000 up to 10,000,000 - 40%
  • over TWD 10,000,000 - 45%

An 18% withholding tax applies for non-resident salary and wage income, and a 20% rate generally applies for other income types. However, foreign national who stay in Taiwan for 183 days or more in a year are treated as residents for individual income tax purposes.

United Kingdom

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Scotland Announces Land and Buildings Transactions Tax Rates

The Scottish Government has announced the rates for the new land and buildings transactions tax. The rates are set under the tax authority of Revenue Scotland, which was established by the Revenue Scotland and Tax Powers Act 2014 for the collection of taxes devolved under the Scotland Act 2012. The land and buildings transactions tax replaces the U.K. stamp duty land tax. The marginal rates are as follows:

  • up to £145,000 - 0%

  • £145,001 to £250,000 - 2.0%

  • £250,001 to £325,000 - 5.0%

  • £325,001 to £750,000 - 10.0%

  • £750,001 and over - 12.0%

Revenue Scotland will have official authority and the tax will apply from 1 April 2015. The above rates and bands are subject to Parliamentary approval which is expected in February 2015.

Proposed Changes (3)

European Union-Austria-Belgium-Estonia-France-Germany-Greece-Italy-Portugal-Slovak Republic-Spain-Slovenia

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Austria and Germany Agree on Timeline for Implementation of EU Financial Transactions Tax

According to an announcement published by the Austrian Ministry of Finance, the Finance Ministers of Austria and Germany have agreed to timetable for the introduction of an EU financial transactions tax (FTT). The tax on equities would be introduced from 2016 and the tax on other transactions including bonds from 2017. The tax would be levied at a rate of 0.1% for equities and bonds, and 0.01% for derivatives. The FTT would apply for any investor or company conducting such financial transactions in the 11 EU Member States supporting the tax.

It has also been reported that the French Finance Minister has agreed with the above scope and rates, despite having introduced an alternate proposal in November 2014 that would exclude bonds, and only apply for transaction of shares domiciled in one of the 11 supporting States.

The EU Member States currently supporting the FTT include: Austria, Belgium, Estonia, France, Germany, Greece, Italy, Portugal, the Slovak Republic, Slovenia, and Spain.


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Nigeria Considering Increase in Standard VAT Rate

The Nigerian government is currently considering an increase in the standard VAT rate in order to balance budgets as oil price continue to drop (a key export for Nigeria). The proposal includes an increase in the standard rate from 5% to 10%.


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Spain Planning to Introduce Country by Country Reporting Requirements

Spain's Secretary of State for the Treasury announced on 20 January 2015 that new Corporate Income Tax Regulations are in the works, including the requirement that multinationals submit a country by country (CbC) report in line with Action 13 of the OECD Base Erosion and Profit Shifting (BEPS) project. The government plans to introduce legislation including the requirement in the first half of 2015, and the first report will likely be required with the tax return for the 2016 tax year.

The OECD guidelines for CbC reporting developed as part of BEPS Action 13 are mostly finalized. The report should include information for all jurisdictions in which a multinational operates, including revenue, profit/loss, taxes paid/accrued, number of employees, assets, business activities, and others. Currently, the OECD is working on implementation guidelines, including thresholds and filing mechanisms.


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