Taiwan: NTBNA publishes Guidance on Submission of TP documentation
On 26 February 2019, National Taxation Bureau of the Northern Area (NTBNA), Ministry of Finance of Taiwan has published guidance on the submission of the Master file and Country-by-Country report by MNEs. Here are the key points as follows: The
See MoreTaiwan: NTBND Publishes a clarification on carry forward of losses for exemption from investment income
On 4 March 2019, the National Tax Bureau of the Northern District (NTBND) of the Ministry of Finance of Taiwan issued a clarification on carry-forward of losses for exemption from investment income. Under the clarification following changes
See MoreWorld Tax Brief: March 2019
Hong Kong Incentives for industry/manufacturing: On 27 February 2019, the Secretary of State presented the 2019/2020 Budget to the Legislative Council. The budget cuts profit tax for 2018/19 by 75%, subject to a ceiling of HKD 20,000, giving
See MoreKenya: Court of Appeal explains the decision about Ruling on income “paid” for Withholding tax
On 5 February 2019, the Kenyan Court of Appeal issued its ruling on: Kenya Revenue Authority v. The Republic of Kenya (ex parte Fintel Limited). In this case, the Court of Appeal overruled the decision of the High Court that the withholding tax
See MoreHong Kong: Financial Secretary presents 2019/2020 Budget
On 27 February 2019, the Financial Secretary has presented the 2019-20 budget to the Legislative Council. The Budget measures includes the following: -Reducing profits tax by 75% for 2018/19, subject to a ceiling of HKD20,000, effectively giving
See MoreLuxembourg: Tax Authority clarifies the new Permanent Establishment definition
On 22 February 2019, Luxembourg tax authorities issued a new circular (No.19) that clarifies recently added the new Permanent Establishment (PE) definition as set forth in article 16(5) of the Tax Adaptation Law (StAnpG). Under the new paragraph,
See MoreHong Kong: IRD publishes 2018/19 profits tax returns and supplementary forms
On 18 February 2019, the Hong Kong Inland Revenue Department (IRD) has published the sample Profit Tax Returns for 2018/2019 including new Transfer Pricing Disclosure Form and other supplementary forms. The supplementary forms are also provided for
See MoreCosta Rica: MOF publishes resolution on tax residence certificates
On 19 February 2019, Costa Rica's Ministry of Finance (MOF) published a Resolution (was first published in the Official Gazette on 4 February 2019), which provides rules on the determination of tax residence and the issuance of residence
See MoreChile: IRS amends the annual transfer pricing form
The Internal Revenue Service (IRS) has issued a new version of the annual transfer pricing tax return (Form 1907) to be used in 2019, and includes new sections on Country Reporting (CbC). The IRS also added the instructions of the 1907
See MoreEgypt publishes a draft of Consolidated Tax Procedures Act
On 17 February 2019, the Ministry of Finance of Egypt has published a draft consolidated tax procedures Act for public discussion. The Act aims to facilitate the procedures related to the collection of various taxes to prevent multiple procedures
See MorePeru: Tax authority clarifies the scope of CFC rules
On 7 February 2019, the Peruvian Tax Authority published a report (097-2018-SUNAT / 7T00000) clarifying the passive net income attribution of CFC rules to its Peruvian shareholders. The Ministry of Finance simplifies the following issues in the
See MorePortugal: Parliament proposes to implements The Anti-Tax Avoidance Directive
Recently, the Portuguese Government has submitted to Parliament the Bill No.177/XIII introducing changes to the Income Tax Act to implement certain ATAD-1 rules. The bill proposed rules for the limitation of interest deductions and rules for
See MoreSingapore presents Budget for 2019
On 18 February 2019, the Finance Minister of Singapore delivered the Budget for 2019. The main tax-related measures are summarized below: To maintain support to companies in their automation, productivity and scale-up efforts, the 100%
See MoreSaudi Arabia: GAZT approves the transfer Pricing Law
On 15 February 2019, the Board of Directors of General Authority of Zakat and Tax (GAZT) of Saudi published a resolution approving transfer pricing Bylaws as well as an additional FAQs document. The law consists of 26 articles, divided into 12
See MoreSweden: Proposal for the extension of the hybrid match rules submits for comments
On 1 February 2019, the Ministry of Finance has sent a memorandum on referral with a proposal to extend the so-called hybrid rules. The purpose of the rules is to prevent differences in countries legislation being used in cross-border arrangements
See MorePortugal legislates law on automatic exchange of financial information
The Assembly of the Republic of Portugal adopted Legislative Decree 17/2019 on 14 February 2019. The law amends the current implementation of the rules governing the automatic exchange of information in tax matters under Council Directive 2014/107 /
See MoreKenya simplifies the taxation of non-tax profits distributed as dividends
On 8 February 2019, the Kenya Revenue Authority (KRA) published a notice clarifying the new measure introduced by the Finance Act, 2018. The Act introduced a new corporate rate on untaxed gains or profits from which dividends are distributed with
See MoreColombia: DIAN publishes transfer pricing return and other forms for 2019
On 15 January 2019, Directorate of Taxes and National Customs (DIAN) of Colombia published Administrative Regulation 000004 of 2019 to provide the following form for filing a 2019 tax return: Informative transfer pricing return (Form 120);
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