Turkey Tax News
ECJ: Previous Austrian rules discriminating dividends received from third countries are compatible with free movement of capital under grandfathering clause – details
Treaty between South Africa and Turkey – details
ECJ: German thin capitalization rules reclassifying interests paid to substantial shareholders in third States are not incompatible with EC law
Draft Guidance on Transfer Pricing published
Discussion draft on application and interpretation of non-discrimination article of OECD Model – details
International tax conference on CCCTB held in Berlin
Revised Commentary on Article 7 of OECD Model released
ECJ: temporal effects of judgment in Meilicke against Germany should not be limited – details
ECJ: hearing in case regarding Dutch withholding tax on outbound dividends
Company tax regimes of Swiss cantons exempting foreign profits incompatible state aid under EU-Switzerland Agreement
Final Report on Improving the Resolution of Tax Treaty Disputes
Treaty between Turkey and Portugal - details
Withholding tax rates reduced
Report on Attribution of Profits to PEs released
EU Commission progresses infringement actions against Member States for discriminatory taxation of outbound dividends
EU Commission requests Italy not to apply a withholding tax on dividends paid to Netherlands parent companies
EU Commission requests Italy to implement the Interest and Royalties Directive correctly
ECJ holds French withholding tax on outbound dividends incompatible with freedom of establishment
ECJ: previous UK ACT regime regarding outbound dividends compatible with EC fundamental freedoms (ACT IV GLO) – details
Treaty between Turkey and Portugal ratified
Income withholding tax rate for non-residents reduced to zero
European Commission requests Belgium to terminate discriminatory taxation of inbound dividends
European Commission requested Spain to end infringement to the EC Parent-Subsidiary Directive concerning the use of anti-abuse measures
European Commission requests Belgium, Italy, Luxembourg, Netherlands, Portugal and Spain to terminate discriminatory taxation of outbound dividends
European Commission refers Italy and Luxembourg to ECJ for not implementing Directive amending EC Parent-Subsidiary Directive
European Commission decides that Luxembourg's preferential tax regime for 1929 holding companies constitutes incompatible state aid
Corporate tax rate reduction approved
The new Turkish Corporate Income Tax Act No. 5520, wholly revising and introducing substantial amendments to the former Corporate Income Tax Act No. 5422 dated 10 June 1949 has been approved by the parliament on 13 June 2006. The Act has now been sent to the President for approval. Most of the provisions are applicable retroactively from 1 January 2006. Transfer pricing rules, however, will be applied from 1 July 2007.
Treaty between Turkey and Portugal approved
New anti-avoidance measures to be introduced transfer pricing, thin capitalization, CFC
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