Sri Lanka | Main corporate tax rates: The Parliament passed the new income tax law on 7 September 2017. Beginning from 1 April 2018, the corporate income tax (CIT) rates will be revised to a three-tier structure consisting of a lower rate of 14%, the standard rate of 28%, and a higher rate of 40%. Reduced rates: Beginning from 1 April 2018, the lower rate of 14% will be applicable on the profits and income of small and medium enterprises (SMEs) where the turnover does not exceed 50 million Sri Lankan rupees (LKR), export of goods or services, agriculture, and education. Taxation of capital gains: With effect from 1 October 2017, a new capital gains tax will be introduced, charging a flat rate of 10% on the gains derived on disposal of immovable properties, at the time of realization of such gains. Withholding tax on Dividends: With effect from 1 October 2017, an increased 14% tax rate will apply to withholding tax on dividends. Interest: With effect from 1 October 2017, 5%, 10%, and 8% rate apply for individuals and charitable institutions on deposits made. Appeal: From 1 April 2017 the Tax Appeal Commission must determine an appeal within six months of receiving the appeal. See the story in Regfollower |
Taiwan |
Main corporate tax rate: On 1 September 2017, Taiwan MOF announces tax reform proposals. Under the proposal from 2018, the CIT rate will increase from the current 17% to 20%. Surtax: On 1 September 2017, Taiwan MOF announces tax reform proposals. Under the proposal from 2018, the surtax will decrease from the current 10% to 5% on undistributed profits. Withholding tax on dividends: On 1 September 2017, Taiwan MOF announces tax reform proposals. Under the proposal from 2018, the dividend withholding tax rate will increase from the current 20% to 21%, applicable to nonresident recipients. See the story in Regfollower |
Vietnam | Reduced rates: On 8 August 2017, the Ministry of Finance of Vietnam has announced the proposal to launch the tax reform program through two drafts on amending and supplementing the Laws on Corporate Income Tax. If the proposal is approved, small firms with less than VND3bn annual revenue will have the tax reduced to 15%. Whereas firms whose annual revenues range from VND3bn to VND50bn revenue will have to pay tax at a rate of 17%. Thin capitalization rules: On 8 August 2017, the Ministry of Finance of Vietnam has announced the proposal to launch the tax reform program through two drafts on amending and supplementing the Laws on Corporate Income Tax. Under the proposal, thin capitalization rules are introduced to limit the deductibility of interest expense to specific debt to equity ratios of 5:1 for manufacturing, 12:1 for banking and 4:1 for all other sectors. See the story in Regfollower |
Turkey | Corporate tax rate: The Finance Minister on 28 September 2017, submitted a draft law on tax changes to the parliament. Accordingly, an increase in corporation tax rate from 20% to 22% is proposed for companies operating in the finance industry. The changes are expected to enter into force by 2018. See the story in Regfollower |
Hong Kong | Treatment of losses: On 11 September 2017, the Financial Services Development Council (FSDC), published a report which proposes that Hong Kong adopt a group tax loss relief regime with a view to encouraging corporate groups to undertake investment activities in the region. The regime would allow the transfer of current year unrelieved tax losses from one wholly-owned group company to another. If adopted, these new tax rules would have a significant impact on business and investment decision-making in Hong Kong, especially in the context of large corporate groups. See the story in Regfollower |
Guernsey | Central management and control: In Guernsey, the Beneficial Ownership of Legal Persons Law, 2017 (the Law) received Royal Assent on 25 July 2017 and came into force on 15 August 2017. Therefore, from 15 August 2017, the incorporation or creation of any Guernsey Entity will require submission of details of its beneficial owner to the Guernsey Registrar of Beneficial Ownership of Legal Persons (the Registrar). See the story in Regfollower |
Mexico | Sanctions for late payments: On 8th September 2017, Mexico presented the budget proposal and tax reform for 2018. The proposed budget increased Surcharge for late payments from 0.75% to 0.98%. See the story in Regfollower Incentives: On 10 February 2017, the Ministry of Finance announced the creation of special economic zones (ZEEs). Legal entities and individuals with entrepreneurial activities in a ZEE would enjoy an income tax exemption during a 10-year period and a 50% income tax exemption during the following 5 years; a reduction of 25% on social security contributions; special VAT treatment similar to that given to foreign trade transactions; and exemption from customs duties for the introduction of goods into the ZEE. See the story in Regfollower |
Slovak Republic | CFC rule: Recently, the Government of the Slovak Republic has announced rules for controlled foreign companies, which will enter into force on 1 January 2019.Recently, the government of Slovak Republic announces rules for controlled foreign companies which will enter into force from 1 January 2019 onwards. See the story in Regfollower |
UK | Computation of Taxable Income: On 8 September 2017 the UK government published the second Finance Bill of 2017. The second Finance Bill of 2017 provides that the corporation tax deduction for net interest expense and similar financing costs is to be restricted with effect from 1 April 2017. The provisions do not apply to groups with less than GBP 2 million of net interest expense in a year. The interest will be restricted by reference to either a fixed 30% of EBITDA or the group ratio percentage, calculated by dividing the net group interest expense by group EBITDA. These rules replace the existing debt cap rules. Facilitating Tax Evasion: On 8 September 2017, the UK government published the second Finance Bill of 2017. A new penalty is introduced in the second Finance Bill of 2017 for any person enabling the use of abusive tax avoidance arrangements that are later defeated in the Tribunal or Court. The penalty is the amount of consideration receivable by the enabler for their role in relation to the tax avoidance arrangements. The penalty will apply to steps taken by an enabler in relation to arrangements entered into on or after the date of Royal Assent to the Act. See the story in Regfollower |
Australia | Small business: On 18 September 2017, the Australian Government published a draft tax legislation for consultation to clarify that passive investment companies cannot access the lower company tax rate for small businesses. As part of the Government’s Enterprise Tax Plan, the corporate tax rate for small corporate tax entities has been cut to 27.5 percent. The turnover threshold that applies for a corporate tax entity to qualify for the lower corporate tax rate will increase annually from $10 million in the 2016-17 income year to $50 million in the 2018-19 income year. See the story in Regfollower |
Ecuador | Withholding tax rates: Ecuador’s Internal Revenue Service (IRS) has amended the income tax withholding rates at the source. For companies, the capital gains derived through stock exchange in a domestic stock market are subject to an income tax withholding at the rate of 0.2%. As regards non-resident taxpayers, the tax treatment of legal persons and individual taxpayers are both to be withheld at source at the same rate, namely the general rate provided for companies. Taxable events include direct or indirect alienation of shares, other rights (including the license for exploring and exploiting natural resources), companies or permanent establishments located within the territory of Ecuador and listed in Ecuadorian stock market. See the story in Regfollower |
Russia | GAAR: The Federal Tax Service (FTS) on 16 August 2017, issued a Guidance Letter on the application of Russia’s new general anti-avoidance rule (GAAR), which was introduced in July 2017. See the story in Regfollower Late payments of tax due: Russia publishes Notice on increased late payment penalty from 1 October 2017. A taxpayer will be charged a penalty of 20% of the tax due for late tax payment. As a result, with effect from 1 October 2017, interest on late payment of tax by companies is increased to 1/150 (previously 1/300) of the refinancing rate of the Central Bank per day, calculated from the 31st day after the due date of payment. See the story in Regfollower |
Colombia | Late payments of tax due: On 30 August 2017, Colombia has updates interest rate for late payment of income taxes. Accordingly, the late payment of income taxes is subject to 30.22% interest rate and effect from 1 to 30 September 2017. See the story in Regfollower |
Switzerland | Incentives: On 6 September 2017, the Swiss Federal Council initiated the consultation on Tax Proposal 17 (formerly Corporate tax reform III). Accordingly, the cantons will be required to introduce patent box regimes, under which profits from patents and similar rights will be separated from other profits and taxed at a lower level, with the relief to be no more than 90 percent. Moreover, the cantons will be given the option of introducing additional tax deductions of up to 50 percent for research and development activities. See the story in Regfollower |
Italy | GAAR: Italy issues a new anti-abuse rule (GAAR) to enhance legal certainty in tax matters. Consequently, a new decree published in the Official Gazette on 11 August 2017 amended the existing arrangements for the avoidance of tax avoidance under the scheme for the granting of participations, which excluded a doubling of the tax advantage within a group of undertakings. The new decree is particularly applicable in those situations when intra-group transactions involve non-residents and therefore cause a reduction in the amount of the allowance which is provided as a decrease applicable against net taxable income. See the story in Regfollower |
Thailand | PE rules: In Thailand, the principle of permanent establishment rule is not part of the domestic revenue law. This principle is, however, accepted in Thailand’s tax treaties. According to the new Thai rule, a foreign company’s representative office in Thailand is no longer obliged to obtain a foreign business license from the Department of Business Development. Though, the representative office is still subject to other legal and tax compliance rules of Thailand-including the requirement to submit the necessary tax returns in Thailand. See the story in Regfollower |
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France: Draft finance bill for 2018 released
Tax Treaty News: September 2017
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