Belgium Corporate income tax rate: On 29 December 2017, the Belgian corporate tax reform law was published in the official gazette. Under this reform, as from 1 January 2020, the corporate income tax rate will be reduced to 25% from 29.58%.  Besides, as from 1 January 2020, for small enterprises, the first €100,000 of profits will be taxed at a rate of 20% instead of 20.4%.
PE rules: As from 1 January 2020, the meaning of permanent establishment in Belgium will be extended to commissionaires based on the OECD’s base erosion and profit shifting (BEPS) Action plan 1 and 7.
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China Relief from double taxation: China’s State Administration of Taxation has published Circular 84 of 28 December 2017 concerning the determination of foreign tax credits. Circular 84 of 28 December 2017 permits taxpayers retroactively from 1 January 2017 to calculate the foreign tax credit based on aggregate foreign income and aggregate foreign tax, as long as the chosen method is then used for at least five years. The Circular also provides that the indirect tax credit for dividends received from non-resident enterprises (minimum 20% direct/indirect holding) may be determined up to a fifth-tier subsidiary (previously up to the third-tier).
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Incentives: On 21 December 2017, the government of China issued a circular (Cai Shui [2017] No. 88). According to the circular, from 1 January 2017, foreign investor’s profits from resident enterprises in China that are directly reinvested in encouraged investment projects will be entitled to the tax deferral and accordingly be temporarily exempted from withholding tax obligations, if relevant preconditions are fulfilled.
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Ecuador Main corporate tax rate: On 29 December 2017, a tax reform law was published in the Official Gazette. Accordingly, from 2018, the general corporate income tax rate is increased from 22% to 25%. Also, the income tax rate for companies with shareholders resident in tax havens or low-tax jurisdictions is increased from 25% to 28%.
Incentives for small business: On 29 December 2017, a tax reform law was published in the Official Gazette. Under this law, a 3% reduction applies in the tax rate for small and microenterprises. Also, new microenterprises starting activities after 30 December 2017 are granted an income tax exemption for a 3-year period, provided certain conditions are met.
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Hong Kong Incentive for small business: On 29 December 2017, the Inland Revenue introduced two tiered profits tax rate regime. The two-tiered profits tax regime will apply to both corporations and unincorporated businesses commencing from the year of assessment 2018/19. Under the new regime, the profits tax rate for the HKD 2 million of profits of corporations will be lowered to 8.25%.
Transfer pricing rules: Inland Revenue (Amendment) (No. 6) Bill 2017 published on 29 December 2017 sets out rules on transfer pricing documentation including country-by-country reporting, and contains other measures to implement the minimum standards under BEPS.
Other Incentives: The Inland Revenue (Amendment) (No.6) Bill published on 29 December 2017 proposes to modify Hong Kong’s tax relief for various businesses including reinsurance, captive insurance, aircraft leasing, shipping and corporate treasury centers as these were deemed to be harmful preferential tax regimes in their present form by an OECD review in October 2017.
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Ghana Mitigation of penalties:  The Government of Ghana has grants a tax amnesty for a period of eight months, beginning 31 January 2017 and ending 31 August 2018. According to the Tax Amnesty Bill 2017, the Government is introducing the amnesty to exempt taxpayers, who register and file returns within the targeted period from paying penalties and interests for late submission or non-submission of returns as well as non-payment of taxes.
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Iceland  Withholding rates on dividends: On 29 December 2017, the parliament approved the Budget for 2018.Accordingly, from 2018, the withholding tax on dividend income increased from 20% from 22%.
Withholding rates on interest: On 29 December 2017, the parliament approved the Budget for 2018.Accordingly, from 2018, the withholding tax on interest income increased from 20% from 22%.
Withholding rates on royalties: On 29 December 2017, the parliament approved the Budget for 2018.Accordingly, from 2018, the withholding tax on royalties income increased from 20% from 22%.
Withholding rates on technical services fees: On 29 December 2017, the parliament approved the Budget for 2018.Accordingly, from 2018, the withholding tax on technical services fees increased from 20% from 22%.
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Italy The Italian Budget Law for 2018 (Law no. 205 of 27 December 2017) published on 29 December 2017 and entered into force on 1 January 2018. Accordingly following changes are offered:
Incentive for Industry/manufacturing: As from 2018, Enterprises may benefit from a tax credit equal to 40% of personnel expenses incurred for certain training activities, related to the Industry Plan 4.0 promoted by the government and agreed through corporate or territorial collective agreements, up to a yearly amount of EUR 300,000 per enterprise.
Incentive for small business: As from 2018, small and medium-sized enterprises (SMEs) may benefit from a tax credit, up to EUR 500,000, equal to 50% of advisory expenses incurred until 31 December 2020 in order to obtain a listing in a regulated market or multilateral trading facility established in a EU Member State or in an EEA country.
PE rule: As from 2018, the budget law includes a broader definition of permanent establishment (PE) in order to make it fully consistent with that proposed by the OECD in the BEPS Action 7 Final Report.
Filing returns: The deadline for submitting the corporate income tax return, the regional tax on productive activities return and the withholding tax return for tax year 2017 has been postponed to 31 October 2018.
Statute of limitations for tax audit: The statute of limitations period is reduced by 2 years for taxpayers that guarantee the traceability of payments made and received for amounts exceeding EUR 500.
Taxation of capital gains: As from 1 January 2019, the non-resident entities will be subject to a final 26% substitute tax on capital gains realized on substantial shareholdings in Italian resident companies, unless a double tax treaty prevents Italy from taxing the gain.
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Jamaica Filing return/E-filing: Tax Administration Jamaica has extended the Tax Return forms due date for the year of assessment 2017 until 15 March 2018.  It is also mandatory for all taxpayers with annual turnover greater than or equal to five hundred million dollars ($500,000,000) to electronically file their income tax returns and declarations of estimated income tax.
Sanctions for late compliance: A penalty of $5,000 per month or part thereof, up to a maximum of $1 million, will be imposed for late filing of income tax returns and declarations of estimated income tax. This penalty will be imposed on the taxpayer automatically if the due date for filing (March 15) is missed.
Sanctions for late payment: Failure to pay the total tax due, attracts a penalty of 1.5% of the tax outstanding for each month (or part of the month) that the tax remains unpaid.
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Kazakhstan PE rule: Kazakhstan adopted a new tax code on 25 December 2017. Therefore, as from 1 January 2018, the definition of permanent establishment is expanded to cover commissionaire arrangements and other agency arrangements in line with BEPS Action 7.
CFC rule: As from 1 January 2018, the direct or indirect ownership threshold for a foreign company is increased to 25% from 10% for considered it as CFC. Controlled jurisdictions will contain any jurisdiction, in which the relevant company is subject to an average effective income tax rate of less than 10% for the reporting period and preceding two tax periods. Again, income tax paid by a CFC in other jurisdictions at the rate lower than 20% will be eligible for offset against Kazakhstani income tax liability. Resident companies that owned no less than 25% in a CFC before 1 January 2018 submit a standard form notification to the tax authorities by 31 December 2018.
Tax Incentives for small business: Kazakhstan adopted a new tax code on 25 December 2017. From 1 January 2018, the new tax Code amended the corporate tax exemption for companies operating in special economic zones. The exemption only applies for income from qualifying transactions, along with the requirement to keep separate tax accounting for exempt and non-exempt income.
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Korea Rep Of Main corporate tax rate: On 19 December 2017, Korea passed the 2018 Tax Reform Act after it was passed by the Korean National Assembly on 5 December 2017. The tax reform 2018 contains provisions in line with the BEPS Action 2 and Action 4 of the OECD. The tax reform includes a new 25% corporate income tax bracket for taxable income in excess of KRW300 billion (US$270 million) . In addition, a local income tax surcharge of 10% will be levied on the current and amended corporation tax rates.
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Lithuania Incentive for Industry/manufacturing:  On 5 December 2017, Lithuania adopted the Budget measures for 2018. Under the new budget from 2018, companies would be able to deduct 100% (Currently 50%) of their taxable profit under the investment projects incentive until 2023.
Incentives for small business: On 5 December 2017, Lithuania was adopted the Budget measures for 2018. Accordingly, the corporate income tax rate of 0% will be applied to small size companies from 2018 subject to subject to certain conditions.
Others Incentive: On 5 December 2017, Lithuania adopted the Budget measures for 2018. Under the amendments, the application of the reduced 5% corporate income tax rate to agricultural companies will be changed from 2018. Under the new law, not all agricultural companies would be able to apply the reduced 5% corporate income tax (as currently set by the Law) but only cooperative agricultural companies, provided that more than 50% of their income is derived from agricultural activities during the relevant tax period, subject to further conditions.
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Philippines Main Corporate tax rate: On 9 January 2018, the Philippines Department of Finance (DOF) released the second package of the tax reform as part of the country’s broader Comprehensive Tax Reform Program (CTRP). Under the Package Two, the DOF aims to lower the CIT rate from 30% to 25% and changes to make incentives more performance-based, targeted, time-bound, and transparent.
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Slovak Republic PE rule: Slovak Presidents has approved the Amendments to Income Tax Act No. 595/2003 Coll. on Income Tax on 20 December 2017. Most of the amendments entered into force from 1 January 2018. The amendment extends the current definition of permanent establishment and changes the conditions for creation of construction and agent permanent establishment.
CFC rule: The amendment introduces the rules for controlled foreign companies (CFC Rules). The CFC Rules introduce taxation of income paid out by the Slovak parent company to its controlled foreign corporation and this income is paid out without any economic substance or in order to obtain any tax advantage for the Slovak taxpayer.
Participation exemption on capital gains: The amendment introduces an exemption from corporate income tax if the income resulting from the sale of shares or business shares for a defined range of taxpayers who meet certain conditions.
Patent box regimes: A patent box as a special tax regime introduced to support the industrial research and development sector. Therefore, 50% of income for the use of granted and registered patents, software or utility models created by the taxpayer as well as 50% of revenues from the licence fees for provision of such intangible assets would be exempt from a tax.
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Taiwan Main corporate tax rate: On 18 January 2018, the Legislative Yuan passed the third income tax optimization plan and is retroactively effective from 1 January 2018. Accordingly, the main corporate tax rate for 2018 is 20%. Additionally, the corporate tax rate with a progression for SMEs with taxable income of up to TWD 500,000: -18% in 2018, 19% in 2019, and 20% from 2020.
Surcharge:  From 2018, a 5% surtax imposed on undistributed earnings.
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