Argentina Main corporate income tax rate: On 31 October 2017, Argentina’s Minister of the Treasury, announced a tax reform plan that would gradually reduce the corporate income tax rate for reinvested earnings. The rate would be gradually reduced from 35% to 30% in 2019 and 2020, and 25% in 2021 and ongoing. There are also plans for reductions in employer social security taxes.
Taxation of capital gains: The government is also planning a 15% capital gains tax on profits from foreign currency instruments and a 5% CGT on peso fixed-income instruments.
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Belgium Participation relief: On 27 October 2017, Belgian Government approves draft law on corporate tax reform including participation exemption. From 1 January 2018, Belgium will grant a 100% participation exemption on dividends (instead of the current 95%). Capital gains on shares will also be fully exempt as of 2018. The separate tax rate of 0.412% on capital gains on shares (shareholding more than one year) will be abolished.
Group reporting: On 27 October 2017, Belgian Government approves draft law on corporate tax reform. Accordingly, from 1 January 2020, Belgium will introduce a tax consolidation regime. The new rules will apply to Belgian resident companies as well as Belgian establishments of foreign companies resident in a Member State of the European Economic Area (EEA).
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China Incentive for industry/manufacturing: China publishes a new circular to support technology industry. The new Circular extended the existing tax incentive to qualifying enterprises nationwide with retroactive effect from 1 January 2017. To obtain the tax benefit a company must submit an application to the local tax authority.
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Incentive for Small business: Tax incentives will be expanded in China to reduce costs for agriculture-related and small-scale businesses. According to an announcement, small and micro-sized enterprises, with monthly sales of 20,000 to 30,000 yuan ($3,050-$4,575), will be exempted from value-added tax from the beginning of next year until the end of 2020.
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Colombia Late payments of tax due: The Colombian Tax Authority has announced that the annual interest rate for late tax payments for 1 to 30 November 2017 is reduced from 29.73% to 29.44%. The rate is based on the rate set by the Financial Superintendence of Colombia through Resolution No. 1447 of 27 October 2017.
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Ecuador Tax payment procedures: On 20 November 2017, Ecuador’s President published a Decree which provides a reduction of income tax advance payments for tax year 2017. Accordingly, a 100% reduction is offered for companies with an annual income or turnover equal or greater than USD 500,000. A 60% reduction is offered for companies with an annual income or turnover between USD 500,000.01 and USD 1 million and a 40% reduction is offered for companies with an annual income or turnover greater than USD 1,000,000.01.
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France Surcharge: The French government on 2 November 2017 has proposed a temporary surcharge for the largest companies that is meant to offset the cost of pending refunds resulting from the repeal of the 3% tax on profit (dividend) distributions. The exceptional surcharge will be levied at a rate of 15% on corporate income tax due by companies with gross revenue exceeding EUR 1 billion for financial years ending between 31 December 2017 and 30 December 2018.
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Ghana Main corporate income tax rate: Recently, the Finance Minister proposed a reduction of the corporate tax from 25% to 20% for 2018 and plans are in progress to exempt private universities from corporate tax. The government intends to increase revenue collection from property taxes.
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Germany Participation relief: On 25 October 2017, the German Federal Tax Court (decision dated 31 May 2017) ruled in favor of foreign shareholders selling shares in a German corporation. Capital gains realized upon sale of shares in a German resident corporation by non-resident corporate shareholders should be 100% tax-exempt instead of only 95%.
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Hong Kong Incentive for small business: On 11 October 2017, the Chief Executive of Hong Kong proposed a new tax relief for small and medium-sized enterprises (SMEs).  According to the proposal, a new two-tiered profits tax system that would lower the profits tax rate to 8.25% on the first HKD 2 million of profit, and the standard profits tax rate of 16.5% would remain unchanged for profit beyond HKD 2 million. The government is expected to submit draft legislation soon, with a view to implementing the proposals in 2018.
Incentive for industry/manufacturing: On 11 October 2017, the Chief Executive of Hong Kong proposed a new tax incentive to promote innovation and R&D in Hong Kong, and to help Hong Kong to become an “intelligent city”. An additional tax deduction of 300% would be introduced on qualifying R&D expenditure up to HKD 2 million, and an additional 200% deduction on qualifying expenditure exceeding this amount. The government is expected to submit draft legislation soon, with a view to implementing the proposals in 2018.
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Italy Taxation of capital gains: The draft budget law 2018 proposed an increase in taxes applicable to gains realized on the disposal of “qualifying shares” of Italian companies. Accordingly, a “flat” 26% substitute tax would be introduced and the tax treatment would be aligned with the capital gains tax of “non-qualified shares” and gains realized by “physical persons.”  If approved, the provision would be effective as of 1 January 2019 and would specifically affect non-resident entities.
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Poland CFC rule: The Budget Bill for 2018 was approved by the parliament on 27 November 2017. Consequently, as of January 2018, the level of holding for CFC purposes to determine control in a non-resident entity will be increased from the current 25% to 50% as envisaged by the EU anti-tax avoidance directive (ATAD).
Thin capitalization rule: The bill introduces a new restriction in the thin capitalization rules, which limits the deduction of financing costs to 30% of an adjusted tax base. The restriction also applies to the financing of non-affiliated companies. A safe harbor is proposed for financing costs up to PLN120000   yearly. The changes will apply from 1 January 2018.
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Romania Computation of taxable income: On 10 November 2017, the Ordinance amending Tax Code published in the Official Journal. According to the new rule a taxpayer will be subject to corporate income tax at the rate of 16% for transfer of business carried out by a permanent establishment, transfer of assets or transfer of residence. The amended Code will come into force on 1 January 2018.
Incentives for small business: On 10 November 2017, the Ordinance amending Tax Code published in the Official Journal. Accordingly, from 1 January 2018, the turnover below which a company applies the micro-enterprise tax regime will be increased from EUR 500,000 to EUR 1 million. Taxpayers which are currently carrying out exempted activities will be subject to the micro-enterprises taxation regime.
Thin capitalization rules: On 10 November 2017, the Ordinance amending Tax Code published in the Official Journal and the new rules have replaced the current in forced interest deductibility rules. According to the new rule from 1 January 2018, the excess borrowing costs acquired in a fiscal period which exceed the deductible threshold of EUR 200,000 will be deductible for corporate income tax purposes up to the limit of 10% of the calculation base.
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Saudi Arabia Appeal: The General Authority for Zakat and Taxes has issued a circular on implementation of recent tax law amendments relating to tax appeal procedures. Under this explanation, the appeal deadline of 60 days and a taxpayer’s right to appeal to the Board of Grievances has been kept as previous and will continue to apply until further notice.
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Thailand Incentive for Small business: On 31 October 2017, Royal Decree was published allowing small and medium-sized enterprises (SMEs) to claim a double (200%) corporate tax deduction allowance for expenditure paid out for purchasing or hiring computer software programs registered with the Digital Economy Promotion Agency for their 2017-2019 financial years.
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UK Payment procedures: On 21 November 2017, the HMRC published technical guidance which explaining changes to corporation Tax instalment payments by very large companies. Accordingly, for accounting periods that begin on or after 1 April 2019, very large companies (companies with annual taxable profits exceeding GBP 20 million) will pay corporation tax in instalments 4 months earlier than other large companies.
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Incentive for industry/manufacturing: The UK’s autumn budget measures were announced on 22 November 2017. The Research & Development Expenditure Credit (RDEC) rate available to companies claiming under the Large Company R&D scheme is set to rise from 11% to 12% from 1 January 2018.
Withholding tax on royalties: The government is to widen the circumstances in which a royalty payment to non-UK residents is liable to UK income tax. The government intends to bring non-UK resident companies within the scope of UK income tax where goods or services are provided to UK customers and a royalty is paid to a company resident in a no/low tax country. The resulting tax changes are likely to take effect from April 2019.
Taxation of capital gains: When a company disposes of an asset and there is a chargeable gain, for corporation tax purposes the gain is reduced by an indexation allowance. The budget changes provide that when a company makes a chargeable gain on or after 1 January 2018, the indexation allowance will only be calculated up to 31 December 2017 and there will not be any indexation relief for the part of the gain arising after 1 January 2018.
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