Japan PE rules: On 28 March 2018, Japan’s Diet enacted the tax reform plan for 2018 and changes the domestic PE definition in line with BEPS recommendations. The scope of the agent PE would be extended to effectively include commissionaire arrangements within the PE definition. Also a person working mostly for one or two closely related principals would not be within the exception for independent agents. Where activities of a foreign company are more than just preparatory or auxiliary they will constitute a PE.  
Incentives-Industry/manufacturing: On 28 March 2018, the Japanese Diet reportedly passed the legislation for the 2018 Budget. The budget includes a tax credit of up to 20% of increased payroll for large companies that increase wages by at least 3% and a credit of up to 25% for SMEs that increase wages by at least 2.5%. The tax credit applies to fiscal years beginning on or after 1 April 2018 and ending on or before 31 March 2021.
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Austria CFC rules: On 9 April 2018, the Austrian Ministry of Finance published the ministerial draft of an Annual Tax Amendment Act. With this draft, the EU Anti-Tax Avoidance Directive (ATAD) will be implemented in Austrian domestic law and in accordance with the ATAD, CFC taxation will be introduced in Austria for the first time. The CFC rules will be applicable to tax years starting from 1 October 2018 or later.
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Belgium Advance payments due: On 9 April 2018. Belgium has published a notice from the Federal Public Service (SPF) Finance in the Official Gazette that includes an explanation of the rules on advance income tax payments for the 2018 tax year (2019 assessment year). Advance tax payments are due quarterly. For 2018 (assessment year 2019), the standard payment deadlines are 10 April 2018, 10 July 2019, 10 October 2018, and 20 December 2018. For tax periods not following the calendar year, the payment deadlines are adjusted accordingly.
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Colombia CFC rules: Recently, the tax authority of Colombia (DIAN) published a ruling regarding whether the exemption for controlled foreign company (CFC) dividend income paid out of profits from real economic activities will apply if the dividends are paid by a subsidiary of a CFC in Colombia. The situation involved a Colombian resident that held two CFCs that each held a share of another company operating in Colombia.
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Hong Kong Incentives-Industry/manufacturing: On 20 April 2018, IRD gazette the Inland Revenue (Amendment) (No. 3) Bill 2018 to provide for enhanced tax deduction for expenditure incurred by enterprises on qualifying research and development (R&D) activities, in order to encourage more enterprises to conduct R&D activities in Hong Kong.
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India Incentive for small business: On 11 April 2018, the Department of Industrial Policy and Promotion (DIPP) has issued Notification to outline the procedure of application and criteria for a startup to be eligible to apply for tax relief. The Notification has come into effect from the date of its publication in the Official Gazette.
See the story in RegfollowerFiling returns: On 3 April 2018, The Central Board of Direct Taxes (CBDT) has released the new income tax return forms for filing returns for the financial year 2017-18 (Assessment Year 2018-19).
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Indonesia Incentives-Industry/manufacturing: On 29 March 2018, Indonesia’s Minister of Finance (MOF) signed a Regulation (PMK-35) providing new regulations on tax holidays. Accordingly, as from 4 April 2018, the definition of pioneer industry has been expanded to cover 17 sectors. The tax holidays provide more certainty as they provide for a 100% corporate tax exemption for years 5 through 20, depending on the amount of new capital investment.
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Ireland Dividend: On 6 April 2018, Irish Revenue has published E-Brief regarding updated guidance on the dividend withholding tax scheme.
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Luxembourg Incentives-Industry/manufacturing: On 17 April 2018, the Bill on new IP regime adopted by the parliament which will enter into force with retroactive effect as from 1 January 2018. The IP regime introduces a new article 50 ter into the Income Tax Law (ITL) that provides for an 80 percent exemption on income derived from the commercialization of certain intellectual property (IP) rights, as well as a 100 percent exemption from net wealth tax (NWT). The new regime is also fully consistent with all recommendations made by the OECD’s Forum on Harmful Tax Practices, including those set out in the OECD/G20 BEPS Project Action 5 Final Report published in October 2015.
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Malta

Participation relief: The definition of a participating holding has been amended so that the minimum percentage holding of 10% has been reduced to 5%.  Furthermore investments in European Economic Interest Grouping (EEIG) shall also be considered to be participating holdings.
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Mexico Incentives-Industry/manufacturing: Mexico has published two regulations in the Official Journal providing for the creation of two new Special Economic Zones (SEZs), which will enter into force on 19 April 2019. Each decree covers the area of the zones, the tax benefits and incentives as well as the customs duties regulations in the zones. One of the key benefits for eligible operators and investors in the Special Economic Zones is a 100% reduction in the tax rate for the first ten years, followed by a 50% reduction for five years.
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Philippines Corporate tax rate: On 21 March, 2018, the corporate tax reform bill presented to the Philippines House of Representatives. The bill aims to reduce corporate tax rates by modernizing tax incentives for investment and removing excessive tax exemptions and privileges. Accordingly, the Bill proposed to reduce the current 30% corporate income tax rate by one percentage point every year beginning 1 January 2019, provided that the rate will not be lower than 20%.
Withholding tax rates: The bill also proposed a 15% withholding tax rate (current 7.5%), on interest income of foreign corporations’ branches in Philippine. Withholding tax on dividends, royalties and service income by reduced 1% point every year starting 1st January 2019, provided that the rate will not be lower than 20%.
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Saudi Arabia Incentives-Industry/manufacturing: On 28 March 2018, the Royal Decree No. M/70 has been issued based on Saudi Arabia’s Council of Ministers’ resolution No. 369 dated 27 March 2018 regarding investments in natural gas. Accordingly, taxable activities of natural gas investment companies will now be subject to Corporate Income Tax (CIT) at a rate of 20%, and not 30% as per the original law.
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