Taxation News – foreign tax credit

Taxation News – 2nd Issue (February 2014)-Necessary documentation needed regarding foreign tax credit

Albania

The new tax rates for Corporate Income Tax and Personal Income tax

Bulgaria

Amendment in the tax treatment of the relations between resident persons and companies registered in jurisdictions with preferential fiscal arrangements

European Union

Mandatory Automatic Exchange of Information

Greece

Necessary documentation needed regarding foreign tax credit

The Ministry of Finance with circular no. 1026/22.01.2014 seeks to clarify the necessary documentation
needed regarding the credit of foreign tax as per the provision of art. 9 (1) of l. 4172/13.
Any taxpayer resident in Greece that realizes foreign income which has been subject to taxation at the
country of source, in order to receive the appropriate foreign tax credit, ought to submit to the competent
authority the following documentation:

  • In regard to countries that Greece has signed a Double Taxation Treaty with, a certificate issued by
    the foreign competent authority ascertaining the tax already paid.
  • In regard to countries that Greece has not signed a Double Taxation Treaty with, a certificate either
    from the foreign competent authority or a chartered accountant.
  • In the case of withholding tax on foreign income, a certificate issued by the person withholding the
    tax authenticated by the competent authority or a chartered accountant. Authentication is not needed
    when the tax is withheld by a public body, insurance company or a financial institution.

If the country of source has signed the Apostille Convention, the certificate has to be supplemented with
the Apostille seal. In regard to the rest of the countries, authentication may be given by the Greek
Consulate. The certificate is submitted in its original form accompanied by an official translation in Greek.

OECD

Discussion Draft on transfer pricing documentation and country-by-country reporting released for public comment

Poland

New time limits for issuing VAT invoices

Romania

  • Artificial transactions criteria
  • VAT amendments
  • Additional tax imposed on income from leases
  • Payment from damages awarded
  • Offsetting of payments with taxes owed

Ukraine

  • A new treaty for the avoidance of double taxation (“DTT”) entered into force between Cyprus and Ukraine on January 01, 2014
  • Enlargement of transparency countries list on exchange of tax database

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