Switzerland: Ordinance on exchange of CbC reports adopted
On 29 September 2017, Swiss Federal Council adopted an ordinance on the international automatic exchange of country-by-country reports on multinational firms. The exchange of country-by-country reports between Switzerland and its partner states
See MoreJapan publishes guidance for taxpayers on the MAPs
Recently, the National Tax Agency of Japan has released a guidance on mutual agreement procedures (MAP) on their website. This guidance has been prepared based on the recommendation 2.1 indicated in the final report on Action 14 (Making Dispute
See MoreOECD: Forum on Tax Administration meets to discuss tax priorities
The Forum on Tax Administration (FTA) discussed tax issues at its plenary meeting on 27 to 29 September 2017. The FTA includes the Tax Commissioners of fifty tax administrations covering industrialized and emerging economies including the OECD and
See MoreOECD: Peer review reports on dispute resolution mechanisms
On 26 September 2017 the OECD released six peer review reports evaluating efforts to improve dispute resolution mechanisms. The reports relate to implementation of measures by Belgium, Canada, Netherlands, Switzerland, the UK and the US. A document
See MoreUS: Donald Trump plans to reduce tax burden for corporations and individuals
President Donald Trump proposed on 27 September 2017 the biggest U.S. tax overhaul in three decades. The proposals come in a “framework” for tax reform with the following changes. Individual measures: Seven existing tax brackets collapsed to
See MoreSlovak Republic: Proposed provisions for patent box regime, exit tax, CFC rules
The Government announced several changes in the corporate taxation area on June 20, 2017, including the introduction of a new patent box regime in line with the modified nexus approach developed as part of BEPS Action 5. The government also proposes
See MoreDTA between Switzerland and Zambia signs
The Double Taxation Agreement (DTA) between Switzerland and Zambia was signed in Lusaka on 29 August 2017. Once in force and effective, the new treaty will replace the existing DTA of 1954. The agreement contains Dividends rate 5% for at least 10%
See MoreTurkey: Government introduces new tax plan
The Finance Minister, Naci Ağbal, announced significant tax increases on September 27, 2017 during the Medium Term Program meeting (2018-2020). A new legislative proposal increasing corporate income tax from 20% to 22% for financial sector and
See MoreUruguay: Regulations on common reporting standard (CRS) issued
On 25 September 2017, the Tax Authority issued Resolution No. 6.396/017 providing instructions to financial institutions for reporting information under the Common Reporting Standard (CRS) guided by OECD. Under the CRS, Financial institutions are
See MoreHong Kong adopts a new intragroup tax loss transfer regime
According a proposal from high level government advisory panel, Hong Kong adopts a new intragroup tax loss transfer regime. If adopted, these new tax rules would have significant impact on business and investment decision-making in Hong Kong,
See MoreArgentina: General Resolution 4130-E publishes in Official Gazette
The Federal Tax Administration (FTA), on September 20, 2017, published the General Resolution 4130-E in the Official Gazette. It establishes the country-by-country (CbC) guiding framework in Argentina and is applicable to ultimate parent entities of
See MoreGuernsey: The Beneficial Ownership of Legal Persons Law enacted
The Beneficial Ownership of Legal Persons (Guernsey) Law, 2017 came into force on 15 August 2017. The Law establishes the Office of the Registrar of Beneficial Ownership of Legal Persons, sets out the powers and functions of the Registrar, and
See MoreNicaragua: Transfer pricing legislations are in effect as of 30 June 2017
The transfer pricing rules are in effect as of 30 June 2017 which was enacted by the Nicaraguan Congress through Law No. 822 of 2012. Law No. 822, enacted on 12 December 2012, contains the Nicaraguan transfer pricing rules that were intended to
See MoreMalaysia: IRBM publishes sample notification letters for CbC reporting
The Inland Revenue Board of Malaysia (IBRM) has recently published two different sample notification letters for entities subject to the country-by-country (CbC) reporting notification requirement. Two separate sample notifications letters have been
See MoreChina and Norway agree to renegotiate DTA
On 27 September 2017, during a meeting between China’s tax Minister Wang Jun and Norway’s Finance Minister Siv Jensen they agreed to renegotiate the Double Taxation Agreement (DTA) between the two countries. "I am pleased that we agree to start
See MoreDTA between Andorra and Malta enters into force
On 27 September 2017, the Double Taxation Agreement (DTA) between Andorra and Malta was entered into force and it will apply from 1 January 2018. The agreement contains Dividends rate 0%, Interest rate 0% and Royalties rate
See MoreLuxembourg: Tax authority publishes circular on mutual agreement procedure
To set out the procedures for the implementation of the mutual agreement procedure (MAP), on 28 August 2017, the Director of Taxes published Circular L.G. Conv. D.I. No. 60. The MAP intends to eliminate legal and economic double taxation. The MAP
See MoreDTA signs between Belarus and UK
On 26 September 2017, the Double Taxation Agreement (DTA) between Belarus and the United Kingdom was signed, in Minsk. Once in force and effective, the new treaty will replace the existing DTA of 1985. The agreement contains Dividends rate 5%,
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