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22.02.2005
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За последние 60 дней ни разу не выходила


Сайт рассылки: https://www.facebook.com/groups/1043085995763412/
Открыта: 30-05-2002

Автор
Roustam Vakhitov

Статистика

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International Taxation - News International Taxation - News


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Здравствуйте-здравствуйте, дорогие подписчики.

Хочу поделиться с вами наблюдениями за Средней Азией и Кавказом по итогам 2004 года (обзор по Казахстану основан на клиентской рассылке KPMG Janat LLC, к слову очень душевные и грамотные люди). За английский не ругайте, лингвистический редактор еще не проверял. Если что-то упустил - пишите, адрес см. ниже.

Звонил тут на днях туркменским налоговикам, говорят что использовали международный опыт при составлении своего brand-new НК (я почему-то и сам так сразу и подумал). Надо больше общаться и делиться опытом, раз уж и Туркменистан за это дело взялся.

Хочу и я внести свою лепту. Вопрос к публике: какую книгу на русском языке о международном налогообложении и/или налоговых режимах зарубежных стран вы больше всего хотели бы видеть в своей библиотеке? Раньше я  больше статьями занимался, а сейчас хочу замахнуться на книжку. Материала - навалом, только неясно что людям больше всего было бы интересно в Казахстане, России, Украине ну и других не менее уважаемых странах СНГ.

Предложения с благодарностью принимаются по адресу vakhitov@gmail.com

Всех благ

Р.Вахитов

In 2004  intention  to create or maintain simple and efficient tax systems seem to remain the major driving force in all Caucasus and Central Asian countries. Those countries where due to various reasons tax reforms were postponed in 2003 (Georgia and Turkmenistan) introduced very liberal Tax Codes.  Other countries continued improve tax administration and introduced new tax incentives with purpose to encourage investment.

 

Where available, new incentives and decrease of general tax rates has been made at the cost of increasing taxation of mineral industries (Kazakhstan, Uzbekistan).


Among these countries only Kyrgyzstan considers further structural tax reform, which is expected to be accomplished in 2005, and Armenia (the only country among discussed applying number of tax laws instead of the single Tax Code) considers introduction of such a Tax Code.

Other countries established more or less stable tax systems and now perform its fine tuning.

 

Armenia

 

The only one small amendment in taxation was reduction of a simplified tax rate ( applicable to small businesses) from 7%/12% to 5%.

 

Armenia signed a tax treaty with Canada and the tax treaty with Austria entered into force.

 

 

Azerbaijan

 

There were no significant changes introduced into the tax system. Mainly the rules on tax administration were improved, in particular almost  all income paid to individuals without registration with the tax authorities become subject to withholding tax. New penalties were introduced for not notifying the tax authorities on the change of location of a legal entity.

  

Rates of royalties for certain minerals  established as a percentage of value of extracted minerals were replaced with fixed rates per metrical unit of its volume, thus simplifying control over mineral royalty payments. In connection with the introduction of a new transport tax (based on the engine capacity of a vehicle)  on owners/users of vehicles, assets tax is no longer payable in respect of vehicles.

 

International aspects: it is clearly stated now that Azeri nationals who are not residents in Azerbaijan are not subject to tax from employment income from non-Azeri sources.

 

Treaties with Lithuania, Italy, Belgium were signed and treaties with Lithuania and Romania  entered into force in 2004.  

 

Georgia

 

As was indicated in Annual 2004 report, legislative process in Georgia had other than tax policy priorities in the end of 2003. As it was expected, in 2004 Georgia introduced a new Tax Code establishing straightforward  tax system consisting of 7 taxes with moderate tax rates (VAT 18% effective from 1 July 2005, individual income tax 12%, corporate income tax 20%, social security contributions 20%).  Tax treaties with Belgium and Italy entered into force and tax treaties with UK and Latvia were signed.

 

Kazakhstan

 

With effect from 1 January 2005 allowable depreciation rates were significantly increased. In addition, several new tax incentives have been introduced.

 

Investment tax concessions

 

From 2005, investment tax concessions may take the form of not only additional tax deductions, but also full exemption from corporate income tax. This full exemption may be granted to newly created taxpayers carrying out activity within the framework of investment projects to establish new production. This tax holiday is designed to stimulate local production.

The period of tax concessions with respect to corporate income tax cannot exceed five years, though the government may establish other periods of tax concessions up to 10 years. For property tax and land tax, tax concessions may be granted for a period of not more than 5 years. It remains to be seen what the conditions will be to qualify for an extended exemption from income tax.

 

Tax treatment of companies that sell goods with high added value

 

The new law singles out the taxation of enterprises selling goods with high added value.

-  taxpayers should calculate the amount of added value as the sum of their payroll expenses, taxes other than indirect taxes and taxes withheld at the source of payment, depreciation charges and net income or loss calculated in accordance with domestic accounting and financial reporting legislation;

-  enterprises selling goods with high added value are entitled to a 30% reduction of their CIT related to such goods. The amount of this tax should be determined on the basis of the proportion of revenues resulting from sales of such goods out of their total revenues.

Enterprises are regarded as selling goods with high added value if:

− their income from the sale of certain goods of their own production (the list of these goods should be established by the government) is not less than 90% of their total sales income;

− their added value is not less than 40% of their total sales income; and

− their tax burden (determined as the amount of taxes for a particular tax period, excluding indirect taxes and taxes withheld at source of payment) is not less than 12% of their sales income.

 

It is unclear how much processing goods must undergo in order to qualify as goods of the producer’s own production, but the benefit is not intended to apply to mere traders.

 

Certain qualifying companies selling goods of their own production are entitled to a 50% reduction in their CIT related to such goods for one year after the introduction of a quality management system.

 

 

 

Regarding individual income tax, certain investment income of individuals from 1 January 2005 became exempt from tax.

 

In respect of mineral taxation due to introduction of various amendments in general tax burden increased, in particular, export of gas condensate became  subject to hydrocarbons export tax.

 

Regarding the  administration of taxes, amount of penalties have  been increased.

 

A tax treaty was signed with Austria.

 

Kyrgyzstan

 

Expected introduction of the new Tax Code in Kyrgyzstan was postponed to 2005 and no substantial amendments occurred to the Tax Code in force. There were several minor changes introduced in particular exemption from tax of interest derived by individuals on bank deposits, exemption from VAT of books and journals in Kyrgyz language. Another important incentive was introduction of zero-VAT rate in respect of works and services performed within projects under certain customs regimes.

 

A tax treaty with Moldova  was signed  and tax treaties with Poland and Finland entered into force.

 

Tajikistan

 

New Tajikistani Tax Code significantly simplified tax system. Agricultural enterprises may elect to pay a single tax instead of 6-7 taxes applicable under the general tax regime.

 

The tax for public transport support is abolished. The tax rate on income of small and medium size enterprises is lowered to 12%. Besides, the Tax Code provides for certain incentives for foreign investors and allows accelerated depreciation.

 

1 Tax treaty was signed and treaties with Germany, Poland and Moldova entered into force.

 

Turkmenistan

 

Turkmenistan introduced a new single Tax Code, replacing several laws on taxation.

 

The Tax Code resembles the Russian Tax Code. However, the provisions on tax administration are stricter and the Code establishes a more simplified tax system. The major taxes are VAT (the general rate 15% and exports, except for export of oil and gas, are zero-rated), excise tax, subsoil use tax (tax rates are 22% and 10% of the value of the extracted natural gas and crude oil, respectively), corporate property tax (1%) and corporate income tax (CIT). Residents (which are defined as legal entities incorporated in Turkmenistan or having therein a place of effective management) are taxed with CIT on their worldwide income and non-residents on income from Turkmenistani sources. The general CIT rate is 8% for private companies and 20% for state enterprises.

 

Transfer pricing rules in their essence permit the tax authorities to make an income adjustment in all cases when the deviation from the market price exceeds 20%. The Tax Code grants extensive powers to the tax authorities. In particular, in cases when they find that the taxpayer intends to evade taxes, they may request immediate payment of the tax.

The definition of a permanent establishment (PE) is based on the definition of the OECD Model. However, there are certain deviations, including the absence of a minimum period for a building site to constitute a PE.

 

The domestic definition of a PE also includes:

–

a storage facility, used for sale or supply of goods;

–

a place related to the exploration of natural resources; and

–

the supply by a non-resident of goods processed in Turkmenistan under certain customs regimes.

To obtain tax treaty benefits, the taxpayer must provide the tax authorities with a confirmation of residence in a treaty state in advance.

Withholding tax on dividends, interest, royalties, insurance premiums, works and services performed in Turkmenistan and certain other items of income from Turkmenistani sources derived by a non-resident are taxable at source at a rate of 15%.

In respect of individuals, the Tax Code provides for a flat rate of individual income tax of 10%. The residence of individuals is defined on the basis of the 183-day test.

 

To avoid double taxation, Turkmenistan provides for ordinary tax credit in respect of income and capital taxes paid abroad.

 

A tax treaty with Belarus entered into force.

 

Uzbekistan

 

The general corporate income tax rate reduced from 18% to 15%, thus making the general CIT rates one of the lowest in the region.

 

Mandatory contribution for development of school education at the rate of 1% of net sales has been introduced, as well as individual accumulative pension accounts, to which employers must make contributions in the amount of 1% of the wages of employees. However, along with reduction of other obligatory social security contributions by 2% this did not increase tax burden.

 

Land tax, subsurface use tax rates were increased significantly.

 

Regarding international aspects - definition of taxable income of individuals has been changed. Previously it was defined as income from activities in Uzbekistan and now as income from Uzbekistani sources, this bringing domestic definition closer to international standards.

 

A tax treaty with Kuwait was signed and a  tax treaty with Italy entered into force.

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