India: CBDT invites public comments on proposal to amend rules for profit attribution to PE
On 18 April 2019, the Central Board of Direct Taxes (CBDT) released the Committee’s report on profit attribution to a permanent establishment (PE) in India for public consultation, specifically requesting for comments on the conclusions and
See MoreTaiwan: Cabinet passes a draft bill on encouraging repatriation of offshore funds
On 11 April 2019, the Cabinet of Taiwan approved a draft bill regarding the repatriation, use and taxation of offshore installations. The bill now goes to the legislature for review and debate. The draft bill clarifies that repatriated assets
See MoreUkraine: SFS clarifies controlled transactions between a non-resident and its PE in Ukraine
On 19 April 2019, the State Fiscal Service (SFS) of Ukraine published a guidance letter 1723/6/99-99-15-02-02-15/IPK on the treatment of transactions between a non-resident and its permanent establishment (PE) in Ukraine as controlled for transfer
See MoreRussia enacts law regarding taxation of capital gains
Recently, the Russian government has enacted the Federal Law No. 63-FZ of 15 April 15 "On Amendments to the Second Part of the Tax Code of the Russian Federation and Article 9 of the Federal Law". The law slightly changes Article 217 of the Tax
See MoreHong Kong: IRD publishes practice note regarding R&D tax concession
On 11 April 2019, the Inland Revenue Department (“IRD”) published its practice note regarding the research and development (“R&D”) tax concession in Hong Kong. DIPN 55 sets out the IRD’s interpretation of the R&D tax
See MorePuerto Rico publishes Circular regarding new quarterly tax return for withholding Payments for services provided
On 4 April 2019, the Puerto Rican Department of Treasury issued a Circular Letter No. 19-10 regarding new quarterly tax return for withholding Payments for services provided, using a new quarterly return form(Form 480.6 SP-1). The
See MoreColombia publishes a decree on deadline of tax filing returns and tax payment for 2019
On 8 April 2019, Colombia issued Decree 608 of 2019 in the Official Gazette that provides rules on the filing of returns for the net worth tax between 26 September 2019 and 9 October 2019, depending on the last digit of the Tax Identification
See MoreThailand extends e-filing deadline
The Revenue Department of Thailand, announced that, Companies, juristic partnerships, foundation and association or any other legal entity that having accounting periods ending on 31st December 2018 are required by law to file annual corporate
See MoreMexico: Tax Administration issues new incentive for interest on corporate debt bonds
On 29 April 2019, the Mexican Tax Administration (SAT) in its Official Gazette published the Miscellaneous Tax Code (MTR) of 2019. Accordingly, the regulations grants special tax incentive decree for interest on corporate debt bonds. The
See MoreUkraine: SFS clarifies tax treatment of fines and penalties on non-resident incomes
Recently, the State Financial Service of Ukraine published a guidance letter 1137/6/99-99-15-02-02-15/IPK, which explains the tax treatment of fines and penalties on income paid to non-resident for non-compliance or improper performance of an
See MoreGreece revises the law on setting up branches with new incentives
On 1 April 2019, the Greek Parliament passed a new bill (Law 4605/2019 ) which includes amendments to Law 89/1967 on the establishment of branches in Greece by foreign companies, including in relation to allowed business activities and incentives
See MoreIndia issues Notification on CbC exchange agreement with the U.S.
On 25 April 2019, India published Notification No. 37/2019 from the Department of Revenue in an extraordinary version of the Official Gazette. India and USA have signed a Bilateral Competent Authority Agreement and Inter – Governmental Agreement
See MoreLuxembourg: Government publishes budget law for the year of 2019
On 26 April 2019, Luxembourg published the Law of 26 April 2019 in the Official Gazette containing the measures for the 2019 budget. The law lowered the standard corporation tax rate from 18% for the financial year 2018 to 17% for the financial
See MoreLuxembourg deposits its MLI ratification instrument
On 9 April 2019, Luxembourg deposited its instrument of ratification for the multilateral convention to implement tax treaty related measures to prevent base erosion and profit shifting (MLI). The MLI will enter into force for Luxembourg on the
See MoreNetherlands: Draft regulations to revise international tax ruling policy
On 23 April 2019, the Dutch Undersecretary of Finance published a draft Decree containing regulations for the previously announced new Dutch international tax ruling practice. The draft Decree would be effective 1 July 2019. A version of a revised
See MoreIndia: CBDT releases new Income tax return Forms for the Assessment Year 2019-20
On 1 April 2019, the Central Board of Direct Taxes (CBDT) has issued a Notification No.32/2019 to notify the new Income Tax Return (ITR) Forms for Assessment Year 2019-20. The new forms -Sahaj (ITR1) , Form ITR-2, Form ITR-3, Form Sugam -ITR-4,
See MorePhilippines: BIR issues green jobs tax incentive regulations
On 12 April 2019, the Philippines Bureau of Internal Revenue (BIR) has issued revenue regulations (RR) No. 5-2019, which implements the tax incentives provisions of RA No. 10771 (Philippine Green Jobs Act of 2016). The regulation explains
See MoreFrance publishes interest rate for shareholder loan for FY ends between March and June 2019
On 17 April 2019, France published interest rates for entities whose financial year ended between 31 March 2019 and 29 June 2019, which are used to determine the deductibility of interest payments to shareholders. The portion of interest payments
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