Denmark: Publishes new executive order on country-by-country reporting
A Danish executive order No. 1133 dated 27 August 2016 was issued to provide detailed rules on notice requirements and on how the CbC report must be completed. The executive order was effective from 1 September 2016. Notification requirements: i)
See MoreCosta Rica: Tax authority finalize transfer pricing return procedures
Costa Rica has published a resolution in the official gazette to finalize the rules concerning the filing of an annual transfer pricing return for taxpayers qualifying as “large taxpayers” or as “national large companies” or operating under
See MoreMauritius: Budget for 2016-2017 with respect to tax management
The Minister of Finance delivered the Budget speech for 2016-17 to the parliament on 29 July 2016. The most important measures with respect to tax management are summarized below. –The Mauritius Revenue Authority (MRA) Act will be amended so that
See MoreBelgium offers incentives for start-ups
In April 2015, the government of Belgium disclosed a tax shelter plan for the digital economy. If certain conditions are met, this plan provides that investments in new shares of start-ups will be eligible for a tax relief of 30% (SMEs) or 45%
See MoreHong Kong: The Inland Revenue Department clarifies the guidance on corporate treasury centre rules
The Inland Revenue Department issued the Departmental Interpretation and Practice Notes No. 52 (“Taxation of Corporate Treasury Activity”) which sets out the Department’s interpretation and practice in relation to the relevant provisions in
See MoreGreece: Refund of non-final dividend withholding tax
The Public Revenue Authority has published a Document ΔΕΑΦ Β' 1135136 on 15th September 2016 for providing clarifications on the likelihood of a refund of non-final dividend withholding tax paid by legal entities on dividends received. In
See MoreBulgaria: Draft bill on mandatory electronic filing of tax returns
The Finance Ministry has published a draft modifications to the corporate and personal income tax reporting rules, mandatory electronic filing of corporate and personal income tax returns and simplified rules for filing corrective tax returns on
See MoreItaly: Publishes new guidance on CFC regulations
The Italian Tax Authorities issued Protocol No. 143239 (the Protocol) on 16 September 2016, providing further clarifications on CFC legislation, as recently amended by Legislative Decree No. 147 of 14 September 2015 and Law No. 208 of 28 December
See MoreUK: Statistics on patent box tax relief
On 14 September 2016 HMRC released statistics on the uptake of the patent box legislation during the first year it was in force. The legislation went into effect in relation to profits earned after 1 April 2013 and is being phased in gradually with
See MoreBrazil: Decision releases concerning the application of the new Brazilian CFC rules
The Federal Court of Curitiba passed on a decision in relation to Process No. 5005596- 52.2015.4.04.7000/PR on May 6, 2016.The single court judgments finish off that a Brazilian taxpayer may remove from the calculation of its corporate income tax
See MoreUK: Date of Autumn Statement announced
The UK Chancellor of the Exchequer is to announce the Autumn Statement on 23 November 2016. The Autumn Statement is sometimes used to introduce new tax measures or to announce intended legislation for the following year's budget. Often draft
See MoreIMF comments on tax policy of Lithuania
Following a visit to Lithuania from 6 to 12 September 2016 for consultation on economic developments the IMF has issued a press release setting out its preliminary findings. Lithuania’s economic activity is expanding and GDP growth is expected to
See MoreVietnam: Publishes Circular on tax incentives
The Ministry of Finance (MoF) on 17 June 2016, issued Circular No. 83/2016/TT-BTC which provided guidance on the implementation of investment tax incentives with regard to corporate income tax, import tax and non-agricultural land use tax. The key
See MoreArgentina: Publishes significant tax changes
On July 22, 2016, Law 27,260, with special incentives for Argentine taxpayers businesses to report previously unreported foreign and domestic assets, was published in the Argentine Official Gazette. The law includes modifications to various tax
See MoreIMF to support economic reform in Bosnia
On 9 September 2016 the IMF issued a report in relation to Bosnia’s economy following the granting of funds under the Extended Finance Facility to support a more competitive economy to attract investment and create private sector jobs. Bosnia has
See MoreUK given powers to introduce public CbC reporting
The UK Government has accepted a cross-party backbench amendment to Finance Bill 2016 which gives HM Treasury powers to introduce public country-by-country reporting. The amendment allows, but does not compel, HM Treasury to bring forward
See MoreChina: New changes of TP regulations
SAT Bulletin No. 42 published on July 13, 2016 has replaced the existing transfer pricing documentation regulations in Circular Guoshuifa No. 2, known as Circular 2. As per Bulletin 42, two parties will be considered related if they have “other
See MoreFrance-announcement of decrease in income tax rates in 2017 Budget
The government of France announced that the current corporate income tax rate of 33.33% will be reduced in the 2017 fiscal Budget. Starting from 2017, a lower rate of 28% will be applicable to small and medium-sized enterprises (SMEs) for profits
See More