Belgium Taxability of other income:
From 2015 small and medium sized companies may create a “liquidation reserve” from  after-tax profits. The liquidation reserve is immediately subject to a separate tax of 10%. Upon liquidation, no dividend withholding tax is due. However, when the liquidation reserve is distributed before the liquidation and within 5 years after its creation, a dividend withholding tax of 15% is due. When the distribution is more than five years after the creation of the reserve a withholding tax of 5% is due.
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Bulgaria Withholding rates on Interest:
Taxable as business income if the non-resident company has a Bulgarian permanent establishment. Otherwise a 10% withholding tax applies, subject to the provisions of the EU interest and royalties directive and the provisions of double tax treaties. The legislation to fully implement the EU interest and royalties directive was passed on 19 December 2014.
The Bulgarian parliament has adopted the Budget Bill on 19th December 2014 for the year 2015 and this Bill applies as from 1st January 2015. It gives a tax increment on bank deposits from 8% to 10%.
Withholding tax rates on Royalties :
The EU Interest and Royalties Directive (2003/49) have been implemented in Bulgarian law, reducing withholding tax to zero on interest and royalty payments between affiliated EU entities. Previously, during the period of implementation a 5% reduced rate was applied until the end of the year 2014.
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Brazil Withholding rates on Dividend:
Under draft legislation a withholding tax of 15% would apply to dividend distributions from 2016 onwards, increasing to 25% where the recipient is in a low tax  jurisdiction, subject to the provisions of a relevant double tax treaty. From November 2014 the threshold tax rate for a jurisdiction to be defined as a low tax jurisdiction is 17% (previously 20%).
Withholding rates on Interest:
From 1 January 2015 interests are exempt if they conform to the requirements of the EU interest and royalties directive.
Withholding rates on Royalties:
From 1 January 2015 royalties are exempt if they conform to the requirements of the EU interest and royalties directive.
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Ecuador Incentives on Industry/manufacturing:
Enterprises set up in special development zones (ZEDE) are granted a further 5% reduction to the income tax rate. There is an income tax exemption for income derived by new investments in productive industries including producers and refiners of steel, copper, aluminium, paper, petrochemicals and shipyards. The exemption runs for ten years from the first year income is received.
Main corporate tax rates:
The standard corporate tax rate is 22% for companies incorporated in Ecuador and branches of foreign companies in Ecuador. A higher 25% rate applies to companies with shareholders resident in tax havens or low tax jurisdictions. This rate applies to the proportion of profits that corresponds to the shareholdings of the shareholders in tax havens and low tax jurisdictions, but if these own more than 50% of the shares then the 25% rate applies to all the profits of the company. The 25% rate also applies to companies that do not inform the tax authorities about their shareholding structure.
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Peru Withholding rates on Dividend:
The dividend tax rate is 4.1% in dividends on profits earned in 2014; 6.8% in dividends on profits earned in 2015 and 2016; 8% in dividends on profits earned in 2017 and 2018; and 9.3% for dividends on profits earned in 2019. From 2015 loans to shareholders are treated as dividends on the date on which the loan is granted (previously not treated as dividend until 12 months after the loan was granted).
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Japan Ordinary losses carry forward:
Losses may be carried forward for 9 years. This period is to be extended to 10 years in respect of losses incurred on or after 1 April 2017. Losses incurred before 1 April 2015 may be carried forward against 80% of profits in each year. For losses incurred from 1 April 2015 the maximum offset is reduced to 65% of profits and for losses incurred after 1 April 2017 the offset is reduced to 50% of profits. SMEs may offset losses against 100% of profits for the same 9 or 10 year carry forward period.
Participation relief:
From 1 April 2015 the participation exemption is not available where the dividends paid by a subsidiary are deductible in the jurisdiction where the subsidiary is located.
Main corporate tax rates:
The Tax Reform Outline for 2015 includes a provision to reduce corporate income tax from 25.5% to 23.9% for tax years beginning on or after 1 April 2015. The local enterprise tax rate is to be reduced from 7.2% to 6% from 1 April 2015. Also from 1 April 2015 newly established corporations and corporations, emerging from bankruptcy may carry forward, 100% of net operating losses for a seven year period.
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Latvia Taxation of non-resident companies:
From  2015 a company resident in an EU Member State or in a jurisdiction with which Latvia has a double tax treaty in force may, instead of paying (i) the 10% final withholding tax on management and consultancy fees received, or (ii) the 5% final withholding tax on rent received for the use of property in Latvia, opt, upon filing a tax return, to pay 15% corporate tax.
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Portugal Main corporate tax rates:
On 31 December 2015, the Budget Law for 2015 (Law 82-B/2014 of 31 December 2014) was published in the Official Gazette. The main tax amendments included in the Law are:  Corporate income tax. The corporate income tax rate is reduced from 23% to 21%.
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South Africa  Withholding rates on interest:
From 1 March 2015, interest payable by South African residents to or for the benefit of foreign persons may be subject to “interest withholding tax” (IWT) at a rate of 15%. The IWT provisions will apply to interest that is paid or becomes due and payable on or after 1 March 2015.
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Ecuador Withholding tax rate:
The new legislation also recasts loans made by Ecuadorian companies to nonresident shareholders as dividends and, therefore, subject to Ecuadorian withholding tax.The applicable domestic withholding tax rate on dividends is limited to the difference between the Ecuadorian income tax rate on individuals (35%) and the general corporate income tax rate (22%). As a result, withholding tax rate cannot exceed 13%.
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Poland Penalties:
According to the original proposal of the Council of Ministers, the proposition of a reduced penalty rate of 55% (the standard rate is 75%) for a voluntary disclosure of undeclared income as well as the extension of the limitation period with regard to such income to 10 years (the general period is 5 years) are not included in the final draft law, which has been presented to the higher chamber of the parliament and the president. Once signed by the president and published in the Official Gazette, the law will generally enter into force on 1 January 2016.
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Chile Thin capitalization rules:
From 1 January 2015, thin capitalization rules are governed by a new article 41 F of the LIR. Thin capitalization rules provide that “outbound interest” paid on excessive debt is subject to a final tax at a rate of 35%. The payer of the interest is liable for this tax. Also a debt is deemed to be excessive on that part that exceeds a debt/equity ratio of 3:1.
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