Peru Corporate tax rate: On August 2016 the Government of Peru presents a bill to the parliament with the intention to increase corporate income tax for large and medium-sized companies but to reduce it for small companies. The standard rate for large companies  would be returned to 30% from  28%, while the rate for small companies would be 10% for 10 years.
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Netherlands Corporate income tax rate: On 20 September, the Dutch government publishes its Budget 2017 containing the Tax Plan 2017 which includes certain amendments to Dutch tax law.  At present, the corporate income tax rate is 20% on the taxable amount up to EUR 200,000 and 25% on the excess. The legislative proposals extend the 20% bracket to EUR 250,000 in 2018, to EUR 300,000 in 2020 and to EUR 350,000 as from 2021.
Dividend withholding tax: Under the proposed changes to the Dividend withholding tax treatment of cooperatives, distributions by international holding cooperatives to members that have an interest of 5% or more in the cooperative will in principle become subject to DWT at the standard 15% rate. However, a Dutch domestic exemption will apply in active business structures that are not abusive. The letter also proposes to effectively extend this exemption to shareholders that have a shareholding of 5% or more in the nominal paid-up capital of NVs and BVs.
Incentives: The 2017 Budget also introduces changes to the Dutch innovation box. The Dutch innovation box regime creates an attractive research and development environment in the Netherlands by allowing certain profits derived from qualifying intangibles to be taxed at an effective 5% rate insofar as those benefits exceed the production costs of the intangibles. The innovation box regime, therefore, leads to a significant reduction of the general CIT rate of 25%. Following the OECD’s BEPS Action 5 (Countering Harmful Tax Practices More Efficiently), states are required to implement changes to their intellectual property (”IP”)-tax regimes concerning the access to such regimes and economic substance.
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France Corporate income tax rate: On 28 September 2016, the French Government presented the draft Finance Bill for 2017. According to the draft bill,  The French corporate income tax (CIT) rate would decrease from 33.3% to 28%. The 28% CIT rate would be progressively extended to all entities as follows: : (1) for financial years opened as from 1 January 2017, the 28% new rate would apply to the portion of the profits of small and medium enterprises up to €75,000; (2) for financial years opened as from 1 January 2018, the new rate would apply to the portion of profits up to €500,000 earned over a 12-month period; (3) for financial years opened as from 1 January 2019, the 28% rate would apply to all profits for companies with revenue (or revenue of a French tax group if such group exists) below €1 billion, and up to €500,000 of profits for companies with revenues in excess of €1 billion, in both cases for a 12-month period. The new rate would finally apply to all companies for the financial years opened as from 1 January 2020.
Surcharge on the corporate tax: According to the draft bill, the 10.7% surcharge on the corporate tax, paid by companies or French tax groups with revenues exceeding €250 million would no longer apply for the financial years closed as from 31 December 2016.
Payment of tax by large companies: According to the draft bill, companies with revenues in excess of €250 million are required to remit and pay their corporate income tax in five instalments during the year. The amount of the fifth instalment currently is equal to the difference between 75% and 95% (depending on the amount of the company’s revenue) of the company’s estimated corporate tax liability for the current year and a number of instalments already paid. These percentages would be replaced by and increased by 80% to 98%, with the intention to accelerate the payment of the amount of corporate tax due by the largest companies.
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Greece Refunds rule of non-final dividend withholding tax: On 15 September 2016, the Public Revenue Authority published the Document providing clarifications on the possibility of a refund of non-final dividend withholding tax paid by legal entities on dividends received. According to the Document, where the amount of dividend tax (levied at 10% in 2016 and 15% in 2017) is higher than the amount of corporate income tax (levied at 29%), the difference is not refunded to the taxpayer. The reason for this is that, under the Tax Code, only the amount of tax corresponding to the tax which has been withheld or paid in advance is refunded.
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Egypt Appeal: The Egyptian parliament approves tax resolution law aimed at easing investment disputes on 30 August 2016. The purpose of the law is to streamline the settlement of pending tax cases. The settlement process would start as soon as an investor submits a request to the tax authority, at which point court proceedings would be suspended for three months or longer if needed. The tax resolution law will expire after one year, a copy of the legislation stated. The draft law will abolish Law No. 163 for 2013 and Law No. 159 for 1997.
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Mauritius Incentives:The budget for 2016 / 2017 was delivered on 29 July 2016 to the National Assembly by the Minister of Finance and Economic Development. According to the budget following tax incentives are available: 8-year tax holiday to new enterprises set up by individuals or co-operative societies under certain qualifying schemes and registered with SMEDA. 4-year tax holiday to existing enterprises registered with SMEDA with a turnover of less than Rs 10 million and engaged in qualifying activities under the same scheme (from the year of assessment 2016/17). Investment tax credit whereby a specified manufacturing company is able to offset against its tax liability 5 percent of the investment in new plants and machinery over 3 years is being overhauled. The minimum eligibility requirement of Rs 100 million investments in a year is being removed. The tax credit will be increased from 5 to 15 percent in respect of manufacturers of textiles, wearing apparels, ships and boats, computers, pharmaceuticals and for film production. New tax holiday of 8 years will be introduced to fishing companies operating from Mauritius.
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Tax administration: The 2016/2017 budget measures with respect to tax administration are:  An Alternative Dispute Resolution mechanism will be set up by the MRA to expedite tax appeal cases exceeding Rs 10 million. An Alternative Dispute Resolution Panel of 3 members will be set up, including a representative of the Attorney General’s Office. Provision will be made to enable the MRA to request high net worth individuals to submit a statement of their assets and liabilities. The Mauritius Revenue Authority Act will be amended to include no submission of tax returns in the definition of ‘fraud’. The non-remittance of VAT, PAYE and other tax deduction at source will constitute a criminal offence. And the penalty provisions also will be strengthened.
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Bulgaria E-filling: On 16 September 2016, the Ministry of Finance published draft amendments relating to the corporate income tax reporting rules, introducing mandatory electronic filing of corporate income tax returns and simplified rules for filing corrective tax returns. The draft bill predicts that the amendments will enter into force on 1st January 2017. According to the proposed amendments, companies will be obliged to file their corporate income tax returns online using a qualified electronic signature.
Submission of returns: The draft bill permits companies to submit a corrective annual tax return by 30 September of the year in which the annual tax return was initially filed. The new rules will grant companies at least 6 months and 5 months, respectively, following the deadline for the filing of their annual tax returns to independently submit a one-off corrective tax return without an intervention by the tax authorities. Filing of such corrective tax returns will be possible only once.
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Italy CFC rules: 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 2015 (the Stability Law for 2016). According to the new legislation, the scope of the CFC rules encompasses companies located in a jurisdiction which is not considered to have a privileged tax regime, provided that the following conditions are met: the actual income tax paid in the foreign jurisdiction is lower than 50% of the Italian corporate income tax that would be applicable to the company if it were resident in Italy, and more than 50% of the proceeds of the controlled foreign company consist of passive income for CFC purposes.
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Interest: The Italian Tax Authorities issued Resolution No. 84/E on 29 September 2016, providing clarifications on the tax treatment of qualifying interest on medium or long-term loans. In general, interest income paid to non-resident banks with no permanent establishment in Italy is subject to a final withholding tax at a rate of 26% or at a reduced rate when a tax treaty applies. However, provided that certain regulatory provisions are respected, no withholding tax is levied on interest on medium or long-term loans granted to enterprises, if the lender is any of the following:
-a bank established under the law of an EU Member State;
-an entity listed in article 2(5), No. 4 to 23, of Directive 2013/36/EU;
-an insurance company established and licensed under the law of an EU Member State; or
-an institutional investor, whether or not subject to tax, set up in a country included in the Italian white list and subject to regulatory supervision in its home country.
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Vietnam Incentives: The Ministry of Finance on 17 June 2016, presented 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. Under the Corporate income tax, qualified scientific and technological enterprises are entitled to an income tax exemption for 4 years or a 50% deduction from CIT for 9 years with certain conditions. First-time projects investing in hotels, offices, residences, audit and consulting services, technical services, supermarkets, golf courses, resorts, amusement parks, clinics and training, and financial institutions will be exempt from import tax on imported goods. Sectors that are subject to special investment incentives, having projects or operations in areas of “very difficult” socio-economic conditions, will be exempt from non-agricultural land use tax. There will be also a 50% reduction in non-agricultural land use tax for qualifying sectors in “difficult” socio-economic conditions.
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Brazil CFC rules: Court decision regarding 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 held that, a Brazilian taxpayer may remove from the calculation of its corporate income tax (CIT) (IRPJ) and social contributions (CSLL), results of its controlled foreign subsidiaries located in Argentina and Chile, until those results are effectively made available to the Brazilian controller. The decision signifies the first time the issue of controlled subsidiary results has been considered under in recent times amended controlled foreign corporation (CFC) rules commenced in May 2014 by Law No. 12,973/2014 and which has applied from January 1, 2015, unless adopted earlier.
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Romania Incentives:Romanian Finance Ministry on 21 September 2016 published a press release stating that it has recently issued proposals for tax incentives for companies. With the proposal, Romania introduces incentives (in the form of tax deductions) to companies supporting professional qualification. Also, Romania extended the application period for the exemption of income reinvested in the production or acquisition of IT and technological equipment utilized for performing economic activities.
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Hong Kong  Computation of taxable income: Hong Kong issued Departmental Interpretation and Practice Notes No. 52 (DIPN 52) on the taxation of corporate treasury activities on 9 September 2016. Under the new law, Hong Kong’s Inland Revenue Department explains: (i) The definition of “intra-group financing business” and (ii) the “subject to tax” requirement that the overseas associated lenders must satisfy before a Hong Kong taxpayer can claim a tax deduction on the interest payment.
Interest income: According to the Inland Revenue (Amendment) (No. 2) Ordinance 2016, under specified conditions, the interest payable on money borrowed by a corporation carrying on an intra-group financing business in Hong Kong is taxable in determining profits liable for profits tax on or after 1 April 2016. In addition,if a corporation (other than a financial institution) lends money to a non-Hong Kong associated corporation in the course of its intra-group financing business carried on in Hong Kong, the interest income and relevant gains or profits derived therefrom will be subject to profits tax.
Incentives: The new law specifies that an 8.25% Concessionary tax rate will only apply to qualifying profits derived from the following qualifying transactions but excludes amounts that can be claimed as a Hong Kong tax deduction by any person if:  Money lent to a non-Hong Kong associated corporation in the ordinary course of an intra-group financing business; A corporate treasury service provided to a non-Hong Kong associated corporation and; A corporate treasury transaction related to the business of a non-Hong Kong associated corporation.
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Uruguay Computation of taxable income: The Ministry of Finance issued Decree No. 279/016 on 12 September 2016 which provides that, 5% of the income derived from advertising and propaganda services rendered abroad by CIT taxpayers to other CIT taxpayers would be considered sourced in Uruguay,provided that up to 10% of the user of the services’ total income is subject to CIT.
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Poland Reduced corporate tax: In August 2016, the Senate approved a bill to introduce a reduced corporate income tax rate of 15% for small taxpayers with revenue worth under EUR1.2m. If enacted, the proposals will take effect from January 1, 2017; however, transitional provisions will apply to taxpayers whose fiscal year does not coincide with the calendar year.
Incentives: From January 1, 2020, a special hydrocarbons tax on the mineral extraction of up to 25% on the difference between turnover and expenses will apply; this rate will be in addition to the corporate income tax. In addition, extraction taxes of either 1.5% or 3% (depending on the location of extraction) for gas and either 3% or 6% for oil (depending on the location of extraction) will also take effect from 2020. From September 1, 2016, an additional tax on the monthly turnover of retailers applies at 0.8% on sales from PLN17m to PLN170m, and 1.4% on sales over PLN170m. In August 2016,the Council of Ministers adopted a bill introducing new research and development (R&D) tax incentives aimed at stimulating the development of R&D activities which proposes to extend the three-year carryforward to six years.
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Belgium Incentives for start-ups: In April 2015, the government of Belgium disclosed an incentive 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% (micro-companies). The investment can be made directly or indirectly through a crowd funding platform or public start-up fund. The investor is required to hold the shares for at least 4 years.
As from the assessment year 2017, the incentives will also be available to special investment companies, not being collective investment companies, whose sole purpose is to invest in specific start-ups at the request of investors. However, for this type of investment, the intervention of a regulated crowd-funding platform is required.
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Sweden Incentives: On 20 September 2016, the Budget for 2017 was presented to the parliament. Accordingly,  the temporary reduction of the taxable values of some green cars is extended until the end of 2020 and the maximum reduction is limited to SEK 10,000 per year.
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