France-ruling on 75% withholding tax on dividends paid to residents of NCSTs in accordance with constitution
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
See MoreHong Kong: IRD explains the appeal process against tax assessment
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
See MoreAustralian government asking for comment on diverted profits tax legislation
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
See MoreProtocol to DTA between Belgium and Canada approved
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
See MoreCyprus: Cyprus signed on Multilateral Competent Authority Agreement
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
See MoreZambia: Draft Budget for 2017
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
See MoreNetherlands: Fourth amending bill presents to lower house of parliament
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
See MoreBahrain- Egypt: Egyptian parliament approves treaty between Bahrain and Egypt
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
See MoreGermany: Publishes social security contributions thresholds for 2017
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
See MoreHong Kong: Government launched a Consultation on measures to counter base erosion and profit shifting
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
See MoreUkraine joins the inclusive framework on BEPS
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
See MoreSpain: New law introducing tax measures addressed to the reduction of the public deficit
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
See MoreIndia: Signs A further five unilateral advance pricing agreements
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
See MoreMalaysia: Budget for 2017
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
See MoreFinland: Income received from China on mobile games treated as royalties
The Finnish supreme administrative court issued an order that income on mobile games received by the Finnish company from the Chinese company, under the agreement, constituted royalties in accordance with the treaty. The issue in this case was
See MoreDenmark: Publishes main tax thresholds for 2010-2017
The Danish Ministry of Taxation published an overview of the tax thresholds applicable in the period from 2010-2017. The main amounts for 2017 are listed below: Corporate income tax: Amount (DKK) limit for the deduction of net financing
See MoreMexico: Publishes tax reform package for 2017
Mexico’s Government on 30 November 2016 Publishes the Decree containing the tax reform package for 2017 in the Official Gazette. The reform will be effective as of 1 January 2017. The main amendments to the income tax law are summarised
See MoreSweden: Submits proposals for the implementation of CbC reporting bill
Proposals for the implementation of country-by-country transfer pricing reporting have been submitted to Sweden's Council on Legislation alongside a draft law to transpose the updated EU Directive on administrative cooperation. According to an
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