Australia GAAR: 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 and associated explanatory material would strengthen the anti-avoidance rules in Part IVA of the Income Tax Assessment Act 1936 and amend the Tax Administration Act 1953 and associated Acts to give effect to the decision.
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Bolivia Audit rules: On 27 November 2016, the National Tax Service publishes audit procedure rules which contain the formalities to be observed by the tax authorities during an audit procedure carried out to verify tax liabilities. The Resolution will enter into force on 27 November 2016.
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Bulgaria E-filing: On 23 November 2016, the parliament supported on the adoption of amendments to the corporate income tax reporting rules proposed on 16 September 2016. The bill has gone through some changes and accordingly, an electronic filing obligation will only be introduced for companies from 1 January 2018, businesses will be required to file their annual corporate tax returns online. As a result, companies will no longer be able to claim the existing 5% discount from their tax liability for electronic filing.
The parliament has also accepted rules allowing companies to submit a corrective annual tax return by 30 September of the year in which the annual tax return was initially filed. These changes will be effective from 1 January 2017.
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Colombia Corporate income tax rate: On 19 October 2016 The Colombian Government has proposed replacing the current corporate income tax, equity tax and equity tax surcharge with a single tax rate that would be implemented gradually as follows:  For 2017, the corporate income tax rate would be 34%, plus a 5% surcharge for those with income of COP800m or more; For 2018, the corporate income tax rate would be 33%, plus a 3% surcharge for those with income of COP800m or more, and  for 2019 onwards the corporate income tax rate would be 32% with no surcharge.
Carry forward period for Losses: The Colombian Government has proposed restricting the loss carry forward period to 8 years.
Withholding tax: The Colombian Government has proposed increasing the 14% default withholding tax rate to 15% on foreign payments.
Withholding tax rate on interest: The Colombian Government has proposed replacing the 33% and 14% interest withholding tax rates with a single 15% withholding tax rate.
Withholding tax rate on dividend: The Colombian Government has proposed introducing a 10% withholding tax on dividends paid to non-residents from profits taxed at the corporate level from 1 January 2017.
Withholding tax rate on royalties: The Colombian Government has proposed reducing the 33% withholding tax rate for royalties to 15%.
Statute of limitations period on tax audits: The Colombian Government has proposed increasing the standard statute of limitations period on tax audits from two years to three years. The statute of limitations period where there is a loss or where loss relief is carried forward would be increased from five years to six years. For taxpayers subject to transfer pricing rules, the statute of limitations period would be six years.
CFC rules: The Colombian Government has proposed the introduction of controlled foreign company (CFC) rules. The CFC rules would apply to resident companies and other taxpayers that (whether alone or together) hold directly or indirectly at least 10% of the capital of a CFC. CFCs would include investment vehicles such as corporations, trusts, mutual funds and private foundations. An entity would automatically qualify as a CFC if it is domiciled, incorporated or in operation in a non-cooperative jurisdiction or low or no tax jurisdiction. Resident companies and taxpayers subject to the CFC rules would be required to pay corporate income tax on the passive income received by the CFC in proportion to their share in the capital of the CFC.
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Croatia Corporate income tax rate: On 4th November 2016, the Tax Administration published proposed amendments to the Corporate Income Tax Law. Accordingly, the corporate income tax rate will be reduced from 20% to 18%. The proposal also introduces a lower corporate income tax rate 12% for entrepreneurs with up to HRK 3 million of gross income in the preceding calendar year and for farmers.
Incentives: With respect to regional tax incentives for business activities in the second category of local government areas will be abolished; and for business activities in the first category of local government areas or in the city of Vukovar, a 50% reduction of the prescribed corporate tax rate will apply.
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Denmark Corporate income tax: The Danish Ministry of Taxation has proposed a threshold for the deduction of net financing expenses and a limit is 21,300,000 and Maximum loss carry-forward limit is 8,025,000.
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France Dividend: On 18 November 2016, the Amending Finance Bill for 2016 was presented by the government and submitted to the National Assembly which introduce a provision which would expand the benefit of an exemption from the 3% tax which is applied to dividend distributions to foreign parent companies (both the French parent companies and the foreign parent companies that satisfy apart from their nationality, the conditions to be the head of a French tax group). According to the proposed amendments, this benefit will be  extended to distributions made to any resident or non-resident parent company with the direct or indirect holding of at least 95% of the capital of the distributing subsidiary. To get this benefit the non-resident parent companies must be subject to corporate income tax and must be located in a state which concluded a convention on administrative assistance with France, excluding non-cooperative states or jurisdictions (NCSTs).
Participation exemption: According to article 30 of the new Finance Bill, the participation exemption for dividends is no longer conditioned upon the parent company holding 5% of the voting rights of the subsidiary. Therefore, dividends from shares with no voting rights may benefit from the participation exemption. However, a requirement relating to the 5% voting rights threshold is introduced with regard to the long-term capital gains regime applicable to certain shares.
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Greece Incentives: The draft law regarding the company establishment under the electronic one-stop shop process was submitted to the parliament on 25th November 2016. The draft law covers a 30% discount in respect of incorporation fee, which is normally paid by companies established under the physical one-stop shop process. Also, companies set up under this procedure can be exempt from the incorporation fee for the first year of their operation under certain criteria.
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Hungary Main Corporate tax rate: The Hungarian Ministry of Economy announced on 17 November 2016, a reduction of corporate income tax rates from 2017. The current progressive rate of 10% and 19% will be reduced to a flat rate of 9%. This proposal has been submitted for the approval of employer and employee organisations. If approved, the proposal will be presented to the parliament.
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Israel Main Corporate tax rate: On 31 October 2016, the draft Budget Plan for 2017/2018 (the Draft) was presented by the Minister of Finance. According to the Draft bill, the corporate income tax rate will be  24% in 2017.
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Malaysia Rate reduction for increased revenue: The Malaysian Government has proposed a special corporate tax scheme for years of assessment 2017 and 2018. Under the scheme, taxpayers who increase their revenue by at least 5% compared to the previous year would be entitled to a corporate tax rate reduction as follows:
5% increase for 1% corporate tax rate reduction; 10% increase for 2% corporate tax rate reduction; 15% increase for 3% corporate tax rate reduction; and 20% increase for 4% corporate tax rate reduction. The rate reduction would be applied to the increased revenue.
SME: The Government has also proposed reducing the corporate tax rate for resident SME companies with income up to RM500, 000 from 19% to 18% from 1 January 2017.
Withholding tax exemptions for interest: The Government has proposed removing the withholding tax exemptions for interest arising from an approved loan in Malaysia, or paid or credited to a non-resident company in the same group in respect of securities issued by the government, or in respect of ringgit-denominated Islamic securities and debentures, other than convertible loan stocks, approved by the Securities Commission. If enacted, the changes would apply from the year of assessment 2017.
Penalties for late return: The Government has proposed increasing the penalties for late return filing or late payment of GST as follows: 10% for 30 days or less; an additional 15% for 31 to 60 days and an additional 15% for 61 to 90 days. The provision providing for a maximum penalty of 25% of the GST owed would be removed. The proposed amendments would also clarify that the penalty applies to the GST wholly or partly owed.
Withholding tax on service fees and royalties: The Budget has proposed to amend the Malaysian withholding tax laws to apply a 10% withholding tax to all amounts paid or credited to nonresidents in consideration for services, even if such services are performed outside Malaysia.  In addition, the budget proposes to expand the definition of “royalty” to include any consideration paid for the use of or the right to use software. Accordingly, such amounts will be subject to the 10% domestic royalty withholding tax which may be reduced under tax treaties.
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Mexico Incentives: On 15 November 2016, the Decree which contains the Federal Revenue Law for 2017 approved by the Congress on 20 October 2016 and by the Senate on 26 October 2016 and proposed following tax incentives: (i) Taxpayers engaged exclusively in public and private ground transportation and in touristic activities, that use the national highways, may credit against the income tax 50% of the amount of tolls paid in the same year. For income tax purposes, the amount credited will be considered taxable income.(ii) Taxpayers engaged in mining activities with an annual gross turnover lower than MXN 50 million derived from the sale of minerals and other substances referred to in the Mining Law may credit against the income tax the special duty on mining  paid in the same tax year. (iii)  Taxpayers subject to tax under Chapter II of the Income Tax Law may reduce the tax profit with the profit sharing paid in the same tax year And(iv) Taxpayers benefitting from a cinematographic project tax credit may reduce their income tax advance payments with the amount of such credit.
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Nigeria Incentives: The amended Companies Income Tax Act bill 2015 approved on 16 November 2016 and it has proposed the following additional tax incentives to companies: Companies those are engaged in the mining of solid minerals and gas utilization from 3 years to 5 years can get the increased facility of tax holiday; 10-year tax holiday is provided for new companies those are situated in areas without government-provided infrastructure; increase in the rate of rural investment allowance to be claimed on tarred roads from 15% to 20%.
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Poland Incentives: On 14 November 2016, Poland’s Parliamentary Public Finance Commission presented and voted on a revised bill amending rules for the corporate income tax (CIT) exemption for investment funds. The revised bill gives the CIT exemption to close-ended investment funds, excluding certain types of income. Other funds (open-ended investment funds (FIO), special open-ended investment funds (SFIO) and similar foreign investment funds) will still enjoy full exemption.
GAAR: The revised bill also introduces changes to the general anti-avoidance rules (GAAR) enacted in July 2016. In this respect, the amendment introduces a provision that tax rulings issued prior to the entrance of the GAAR into force will not offer protection if a tax benefit resulting from the ruling is obtained after 1 January 2017.
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Portugal Incentives: The tax authorities published Decree-Law No. 211/2016 on 3 November 2016, which introduces an optional tax regime for the revaluation of tangible fixed assets and investment properties. The Decree-Law creates a new tax incentive through the revaluation of tangible assets used in commercial, industrial or agricultural activities, as well as to investment properties and other tangible assets affected by concession contracts, aiming also to improve the equity of the companies.
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Russia Carry-forward of losses: Russia has adopted in the first hearing draft Law No. 11078-7 (the Law) on 2 November 2016, regarding changes to the Tax Code. Accordingly, the 10-year limitation period for carrying forward losses will be cancelled. The losses to be carried forward will be limited to 30% of the taxable base for the current tax period. The new rules will also affect the entities which are part of a consolidated group of taxpayers. The losses to be carried forward cannot be more than 30% of the taxable base of the profit-making entities which are part of the same consolidated group of taxpayers.
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Spain Tax payments: Royal Decree-Law 2/2016, of 30 September 2016, introducing tax measures aimed at reducing the public deficit, was published in the Official State Gazette of 30 September 2016. The new law is expected to increase the amount of the corporate income tax prepayment significantly for companies with turnover exceeding €10 million during the 12 months prior to the beginning of the tax period, and have an effective date of 30 September 2016. The new measures will Increase the tax rate from 17% to 24% of the taxable base or to 29% for taxpayers in certain industries such as the financial or banking sector, and the oil and gas sector.
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Sri Lanka Corporate income tax rate: The Budget for 2017 was presented to Parliament by the Sri Lankan Government on 10 November 2016. The main measures concerning corporate taxation and the corporate income tax rate are proposed to be revised to create a three-tier structure of 14% for small medium enterprises (SMEs), exporting goods or services, agriculture and education. SMEs will be defined with the specific criteria of having a maximum turnover limit of LKR 500 million per annum for this purpose; 28% for all other sectors including banking and finance, insurance, leasing and related activities; 40% for betting and gaming, liquor and tobacco and the tax rate applicable to funds, charitable institutions, dividends, treasury bonds, treasury bills and any other sector will be increased from 10% to 14%.
Capital Gain Tax: Capital Gain Tax will be introduced at a rate of 10 percent with effect from 1st April 2017.
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