Guidance from Japan’s tax agency relating to tax agreement with Taiwan

November 30, 2016

Japan’s national tax agency on 30 November 2016 released guidance with respect to withholding taxes and forms for application of the mutual exemption provisions for income of foreign residents. The Guidance on an amendment to withholding taxes

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Bolivia: Publishes audit procedure rules

November 30, 2016

The National Tax Service published Resolution No. 10-0032-16 (the Resolution) on 27 November 2016. The Resolution contains the formalities to be observed by the tax authorities during an audit procedure carried out to verify tax liabilities

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Bulgaria: Transfer pricing regulations

November 30, 2016

Bulgaria fully follows and applies the OECD Transfer Pricing (TP) guidelines and has had robust TP rules for several years, but taxpayers must be concerned about the regulations. The TP rules were first announced in the Corporate Income Tax Act

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DTA between Equatorial Guinea and UAE signed 

November 30, 2016

An Income Tax Treaty between the UAE and Equatorial Guinea has been signed on October 19,

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France-ruling on 75% withholding tax on dividends paid to residents of NCSTs in accordance with constitution

November 30, 2016

The Constitutional Court of France delivered its decision (No. 2016-598 QPC, Eurofrance) on 25 November 2016 about the compatibility with the constitution of the 75% withholding tax rate applicable to dividends paid to a resident of a

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Hong Kong: IRD explains the appeal process against tax assessment

November 30, 2016

The Inland Revenue Department has published their revised Interpretation and Practice Note No. 6 to reflect legislative changes to the rights of appeal against tax assessments, which began to be applied from April 1 this year. These notes are issued

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Australian government asking for comment on diverted profits tax legislation

November 30, 2016

In the 2016-17 Budget, the Australian Government announced that it would implement a Diverted Profits Tax (DPT) to impose a 40% penalty tax on profits that have been artificially diverted from Australia by multinationals. This exposure draft Bill

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Protocol to DTA between Belgium and Canada approved

November 30, 2016

The Belgian parliament has approved the amending protocol of Income and Capital Tax Treaty (2002) between Belgium and Canada on 24th November 2016. It was signed on 1st April 2014 for the avoidance of double taxation and the prevention of fiscal

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Cyprus: Cyprus signed on Multilateral Competent Authority Agreement

November 30, 2016

Cyprus signed the Multilateral Competent Authority Agreement (MCAA) (2016) on 1 November 2016, on the automatic exchange of Country-by-Country reports (CbC MCAA). The agreement is based on article 6 of the Convention on Mutual Administrative

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Zambia: Draft Budget for 2017

November 30, 2016

The Minister of Finance submitted the 2017 Draft Budget to the National Assembly on 11 November 2016. The proposed measures regarding to direct taxation as enclosed in the Budget are given below- Corporate taxation: The capital payment rate on

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Netherlands: Fourth amending bill presents to lower house of parliament

November 30, 2016

The fourth amending bill to the Tax Plan 2017 No. 34 522 (No. 37) was released in the Official Gazette on 15 November 2016. It was presented by the Minister of Finance to the lower house of the parliament on 20 September 2016. The major amendment

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Bahrain- Egypt: Egyptian parliament approves treaty between Bahrain and Egypt

November 30, 2016

The Egyptian parliament permitted the Bahrain - Egypt Income Tax Treaty of 2016 on 15 November 2016 and the new treaty will replace the Bahrain - Egypt Income Tax Treaty of

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Germany: Publishes social security contributions thresholds for 2017 

November 30, 2016

The Federal Council approved the regulation concerning the thresholds for social security contributions for 2017 on 25 November 2016, which had been previously approved by the Federal Cabinet on 12 October

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Hong Kong: Government launched a Consultation on measures to counter base erosion and profit shifting

November 30, 2016

The Hong Kong government has launched a public consultation to gauge views on the implementation of the OECD’s anti-base erosion and profit shifting (BEPS) initiatives. Among the proposal is a measure for the adoption of a formal transfer pricing

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Ukraine joins the inclusive framework on BEPS

November 29, 2016

The Inclusive Framework on BEPS welcomed Macau (China), Mauritius and Ukraine bringing to 90 the total number of countries and jurisdictions participating on an equal footing in the Project. Following the first meeting of the Inclusive Framework on

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Spain: New law introducing tax measures addressed to the reduction of the public deficit

November 29, 2016

Royal Decree-Law 2/2016 released on 30 September 2016 focuses on reducing the public deficit by introducing corporate income tax measures that aim at raising revenue. An increase of the rate applicable to corporate income tax “prepayments” tax

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India: Signs A further five unilateral advance pricing agreements

November 29, 2016

India's Central Board of Direct Taxes has entered into a further five unilateral advance pricing agreements (APAs). The APAs were signed on 27 October 2016 with Indian taxpayers operating in various sectors, including manufacturing and

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Malaysia: Budget for 2017

November 29, 2016

The Malaysian Prime Minister announced Malaysia’s 2017 budget on 21 October 2016 highlighting some tax measures including corporate and personal income taxation changes. Highlighting proposals include important changes to the withholding tax

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