India | Main corporate tax rate: The Finance Minister of India presented the Union Budget 2018-19 on 1 February 2018. Accordingly, a reduced corporate income tax rate of 25% will be applied to Indian companies with gross receipts not exceeding INR 2500 million in the previous year. Taxation of capital gains: The budget proposed a 10% tax on long-term capital gains of over Rs 1 lakh rupees without indexation and a short-term capital tax remains at 15%. See the story in Regfollower PE rules: The 2018 budget proposed to amend the definition of a permanent establishment for the taxation of non-resident digital companies operating in India. According to the proposal, a business connection includes a “significant economic presence” in India. See the story in Regfollower |
Argentina | Incentives for small business: The government published a guidance on the tax deduction incentive for investments in qualifying start-ups. The incentive provides for a tax deduction equal to up to 75% of investments made in qualifying companies, limited to 10% of net taxable income per year with the excess carried forward up to five years (85% deduction for certain regions). The incentive is retroactive and includes investments made since July 2016. See the story in Regfollower |
Australia | Sanction for tax evasion: On 7 February 2018, the Australian Taxation Office has released a draft practical compliance guide PCG 2018/D2 concerning Diverted Profits Tax (DPT). The draft Guideline addresses Schedule 1 to the Treasury Laws Amendment Act 2017 which introduced 40% Diverted profits tax rate on artificially diverted profits from Australia by significant global entities (global revenue of AUD 1 billion or more). See the story in Regfollower |
Canada | Incentives for small business: The Finance Minister presents the Federal Budget 2018 on 27 February 2018. The budget revealed new details on the taxation of passive investment income inside private corporations. When companies earn between $50,000 and $150,000 in a given year from passive investments, a reduced amount of their active business income will be eligible for the small business tax rate, which will be 9% in 2019. Note that, the upper limit for business income that can be taxed at the small business rate is $500,000.). Companies exceeding $150,000 in passive income will no longer be eligible for the small business tax rate. Those with passive income under $50,000 will not be affected, as was mentioned in a revised proposal. See the story in Regfollower |
Cyprus | Government bonds: On 14 February 2018, tax department published ten-year government bond’s yield rates by an announcement for the countries of Cyprus, Czech Republic, Germany, India, Latvia, Poland, Romania, Russia, Ukraine, United Arab Emirates and United Kingdom as at 31 December 2016, the relevant date for tax year 2017. See the story in Regfollower |
Denmark | Incentives for industry/manufacturing: The Danish Government on 2 February 2018, announced that corporate income tax deductions for research and development (R & D) expenses will increase from 100 to 101.5% in 2019. It is expected that the deduction of R & D spending in 2026 will gradually increase to 110%. See the story in Regfollower PE rule: On 23 February 2018, the Danish Ministry of Taxation published the bill on corporate taxation. The bill explicitly stating that non-Danish investors engaged in long-term investment, such as through private equity, venture or infrastructure funds, will not have a permanent establishment in Denmark. Thin capitalization rule: The proposed bill provides for the extension of the tax exemption regime for the creditor to situations where the interest deduction of a foreign subsidiary in another EU or EEA Member State has been restricted by the thin capitalization rules. However, the tax exemption may not exceed the limit on the interest deduction that would have been applicable if both companies had been taxable in Denmark. See the story in Regfollower |
Ecuador | Filing return: On 26 January 2018, the Internal Revenue Service (SRI) of Ecuador has published a Resolution to commence the coefficients for presumptive tax assessments for the tax year 2017. The coefficients for 2017, which vary by industry/activity, are 0.1079 to 0.6380 on total revenue; 0.1085 to 0.8526 on total costs and expenses; and 0.0308 to 0.6520 on total assets. See the story in Regfollower |
Japan | Incentives for industry/manufacturing: Japan’s Cabinet has approved a tax reform plan for the next fiscal year and this includes a move to cut the corporate tax rate to 25% for companies that raise their employees’ wages by 3%. For companies investing in improving their productivity or digitization, a further reduction to 20% is likely. See the story in Regfollower |
Netherlands | Main corporate tax rate: The Dutch Government approved fiscal policy agenda on 23 February 2018. According to the Agenda, the current standard Dutch CIT rate will be reduced from 25% to 24% in 2019, to 22.5% in 2020 and to 21% as from 2021. Tax base: The Agenda confirms that the earnings stripping rule of the ATAD will be enacted as from 1st January 2019. This measure will restrict the deductibility of interest on bank or group loans to a maximum of 30% of the earnings before interest, taxes, depreciations and amortizations (EBITDA) limitation with a EUR 1 million safe harbor threshold instead of EUR 3 million as proposed under the Directive. Withholding tax: From 2021, the Netherlands will introduce a withholding tax on outgoing interest and royalty flows to low tax jurisdictions and in abusive situations. This prevents the Netherlands from being used for transfer activities to tax havens. CFC rule: The Netherlands will introduce CFC legislation to comply with the Directive. This legislation will apply if a Dutch company owns a participation of more than 50% in a foreign company and the foreign company is taxed at a rate which is less than half the Dutch rate. If these conditions are met the profits of the CFC pro rata the participation are included in the tax base of the Dutch company. The CFC profits will be added to the profits of the Dutch company and will be based on the arm’s length principle. See the story in Regfollower |
Nigeria | Special rates: On 17 January 2018, the House of Representatives has passed the Petroleum Industry Governance Bill (PIGB). The PIGB is the first of the component parts of the old Petroleum Industry Bill (PIB) which has undergone series of re-drafting and extensive legislative considerations without successful passage into law since 2008. See the story in Regfollower |
Singapore | Main corporate tax rate: The Finance Minister of Singapore presented the Budget for 2018 on 19 February 2018. Accordingly, for year of assessment (YA) 2018, the CIT rebate will be increased to 40% of tax payable, with increased cap at $15,000 (previously a rebate of 20% of tax payable, subject to a cap of $10,000). The CIT rebate has been also extended for another year to YA 2019, but will revert to 20% of tax payable with a cap of SGD 10,000. Incentives for Industry/manufacturing: To support businesses to develop their own innovations, from year of assessment 2019, the Budget will increase the tax deduction for staff costs and consumables incurred on qualifying R&D projects performed in Singapore from 150% to 250%. Incentives for small business: The Start-up Tax Exemption and the Partial Tax Exemption schemes will be amended from YA 2020 so that the tax exemptions under both schemes will be limited to the first SGD 200,000 of chargeable income and for the start-up scheme, a 75% exemption on the first SGD 100,000 of chargeable income will be provided instead of 100%. To encourage businesses, in particular smaller ones, to register and protect their IPs, the tax deduction of IP registration fees will be increased from 100% to 200% from YA 2019, capped at SGD 100,000. See the story in Regfollower |
South Africa | Filing return: In February 2018, The South African Revenue Service issued a Notice of Improvements to the corporate income tax return, effective 26 February 2018. Some enhancements are reflected in the ITR14 itself, and others influence the requirement to submit additional supporting information with the return. See the story in Regfollower Sanction for tax evasion: On the 22 January 2018, the South African Revenue Service released a draft guide on understatement penalties for public comment by 12 February 2018. The aim of the guide is to provide taxpayers with an understanding of understatement penalties and their application. See the story in Regfollower |
U.S. | Main corporate tax rate: The U.S. President signed the Tax Cuts and Jobs Act on 22 December 2017. Under the new law, the corporate tax rate decreased to 21% from the previous maximum 35% from 2018. The new law also repealed the corporate alternative minimum tax (AMT). The Act introduced a base erosion anti-abuse tax (BEAT). Tax Base: The Tax Cuts and Jobs Act introduced a limit on deductible interest for tax purposes for tax years beginning after 31 December 2017. The interest deduction is capped at 30% of earnings before interest, taxes, depreciation and amortization (EBITDA). CFC: The Tax Cuts and Jobs Act introduced a new Section 951A requiring a US shareholder of a CFC to include in its income the global intangible low-taxed income (GILTI) of the CFC. Incentives: The Tax Cuts and Jobs Act extended the additional first year depreciation deduction (known as bonus depreciation). The bonus depreciation is increased from 50% to 100% for the cost of qualified property acquired and placed into service after 27 September 2017 and before 2023. Treatment of Losses: Net operating losses arising in taxable years beginning after 2017 may be carried forward indefinitely. However the use of the NOLs is limited to 80% of the taxable income for the year. Dividends: To reflect the lower corporate tax rate, the Act also reduces the dividends received deduction (“DRD”) rate, from 70% to 50%, and, with respect to subsidiaries in which the corporate shareholder owns 20% or more (but less than 100%), the DRD is reduced from 80% to 65%. See the story in Regfollower |
Transfer Pricing Brief: February 2018
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