The Finnish Government Decided On Significant Changes To Taxation

On 21 March 2013, the Finnish Government reached agreement on central government spending limits for 2014-2017. The Government emphasizes that the solution to the challenges in public finances lies in economic growth and new jobs. The changes will therefore decrease the tax burden of companies but at the same time tighten the taxation on profits taken out of the companies. The measures now decided are to turn the increase in the debt ratio into […]

By |April 16th, 2013|

Canada: Budget 2013: Changes To Personal Income Tax Rules

Budget 2013 proposes a number of changes to the provisions of the Income Tax Act (Canada) (the “Tax Act”) governing the taxation of individuals, including (i) an increase in the lifetime capital gains exemption and the indexing of same to inflation, (ii) a reduction in the dividend tax credit rate for “non-eligible” dividends, (iii) an extension of the reassessment period for participants in certain tax shelter arrangements and tax avoidance transactions, and (iv) measures enabling the […]

By |April 10th, 2013|

Back-To-Back Loans Challenged In Russia

In 2012 a few court cases were held whereby the Russian tax authorities demonstrated their perseverance in identifying if certain tax planning practices are acceptable or abusive.

One recent case which was upheld in the Russian courts was the Eastern Value Partners Limited Case where the back-to-back debt financing activities were challenged in the context of interest withholding tax issues and the applicability of the Russian Cyprus double tax treaty. In 2006, Cyprus company ‘I’ […]

By |April 4th, 2013|