Denmark  Dividends: The Danish Minister of Taxation published a draft bill on 5 October 2015. This draft bill planned to relax the taxation of certain categories of outbound and inbound dividends in order to comply with European Union (EU) law.The proposals will have effect from 1 July 2016.
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Norway Main Corporate Rate: According to the 2016 Fiscal Budget, The Government proposes to reduce the corporate income tax rate from 27% to 25%.
Participation relief: The application of the participation exemption with regards to dividends received by a Norwegian company will no longer apply to the extent that the distribution has been tax deductible at the level of the distributing entity. Instead, the assessment of whether the participation exemption applies is based on the mix of investments carried out by the fund.
Incentives: The current limit of NOK15 million increases to NOK20 million for in-house research and development (R&D), while the cap for procured R&D increases from NOK33 million to NOK40 million under the Norwegian tax incentive scheme for R&D.
Special petroleum tax regime: For companies taxed under the special petroleum tax regime and the hydro power regime, the reduction in corporate tax rate will be balanced by a corresponding increase in the special tax rates for these regimes.
Residency rules: Under the current domestic law, a company is considered to be a tax resident in Norway based on an overall assessment, but the key element has been whether the company is effectively managed from Norway or not. The government has proposed that all companies incorporated in Norway must always be considered to be a tax resident in Norway for domestic law purposes.
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Kenya Withholding tax rate: Rents and Others: According to the Finance Bill for 2015-16, a withholding tax rate of 10% applies to all payments made by a special economic zone enterprise, developer or operator to non-residents; and rent for the use or occupation of immovable property paid to a resident is subject to withholding tax at the rate of 12%.
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France Surtax: In the proposed Finance Bill 2016 the Minister of Finance has confirmed that the surtax will be eliminated at the end of 2016. As a result the maximum effective corporate tax rate will decrease from 38% to 34.43%.
Micro-enterprises: Also the Bill proposes to change the definition of the threshold for micro-enterprises. From now on a micro-enterprise will be defined for this purpose as a company with no more than eleven employees and a turnover not exceeding EUR2m.
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Thailand Main Corporate Rate:  Recently, The Royal Cabinet decided that, the corporate income tax rate will be permanently kept at 20% from 1 January 2016.
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Luxembourg E-filing: The government of Luxembourg announces in a press release on 29 October 2015 that resident companies may file their corporate income tax and net worth tax return electronically. Similarly, individual entrepreneurs may file their local business tax return electronically.
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Malaysia Incentives: – A special reinvestment allowance of 60% of qualifying capital expenditure will be extended to companies engaged in agricultural activities whose reinvestment allowance incentives have expired.
–To promote R&D activities among companies with paid-up capital not exceeding MYR 2.5 million, it is proposed that these companies be allowed to claim a double deduction automatically for R&D project expenditures up to MYR 50,000 for each year of assessment.
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Namibia Rates: The Namibian Minister of Finance submitted the Income Tax Amendment Bill to the National Assembly on 22 September 2015 regarding following measures:
–The corporate tax rate will be reduced to 32%, which will become effective for years of assessment beginning on or after 1 January 2015.
–The withholding tax rate has been proposed to reduce from 25% to 10% and a withholding tax on interest paid or accrued to non-residents has been introduced at a rate of 10%.
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Romania Dividend: The Romanian government is planning to cut dividend taxes from 2016. At present dividend payments are taxed at 16%. This rate will be reduced to 5% from January 1, 2016, rather than from January 1, 2017 as previously planned.
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Czech Republic Participation Relief: The government submits an amendment to the Income Tax Law to the parliament for approval regarding the participation exemption regime. This regime provides that, dividends received by a parent company in the Czech Republic would not be discharged from corporate income tax and such dividends could be treated as deductible by the subsidiary.
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Spain Statute of limitations on tax audit: The duration of inspection proceedings is extended so that the tax auditors have 18 months to process tax audit proceedings commencing as of 12 October 2015. This period is extended to 27 months with certain condition. This 27-month deadline will also apply where tax audit proceedings take in several related taxpayers and such deadline is applicable to any of them individually.
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Italy Controlled foreign company (CFC): Under article 8 of the Legislative Decree, with effect from tax year 2015, profits realized by a non-resident entities are deemed to be the profits of an Italian resident person if: the resident person controls, directly or indirectly, also through trustee companies or interposed third persons, the non-resident entity; and the entity is resident in a jurisdiction that does not allow an adequate exchange of information with the Italian tax authorities and apply a level of taxation which is lower than 50% of that applied in Italy.
Under the new Law, a low-tax jurisdiction for CFC purposes is defined as a jurisdiction whose level of taxation is lower than 50% of the one in Italy. Similarly, a privileged tax regime is defined as a special tax regime which allows a level of taxation lower than 50% of the one in Italy. The ITA is empowered to issue an amended list of low-tax jurisdictions for CFC purposes.
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