World Wide Tax News - Issue 41

On 4 April 2016, the United States Department of the Treasury (“Treasury”) and the Internal Revenue Service (“Service”) published proposed regulations under Internal Revenue Code (“Code”) Section 385 addressing the
characterisation of certain related party debt instruments as debt or equity for United States tax purposes.

Contents:

• UNITED STATES: Internal Revenue Service and Treasury release proposed regulations addressing debt/equity classifications for US tax purposes
• AUSTRALIA: International taxation developments
• INDIA: Budget 2016 / Draft rules for foreign tax credit / Clarification regarding taxability of consortium arrangements
• SINGAPORE: Value creation and innovation incentives
• SRI LANKA: Automation of the tax office
• BELGIUM: Belgian tax law implementing the Tate & Lyle CJEU decision
• DENMARK: A different ruling on permanent establishment
• HUNGARY: Achievements and plans of the electronic monitoring system / More efficient tax audits
• ISRAEL: Updates regarding recent legislation
• ITALY: Alignment of tax rules to OECD's BEPS project - Focus on CbCR and patent box
• UNITED KINGDOM: Tax on profits from trading in or developing UK land
• ARGENTINA: Supreme Court ruling on minimum presumed income tax
• CANADA: 2016 Federal Budget - International tax measures