Peru: Tax administration clarifies the exchange rate applicable to capital gains arising from the transfer of shares
On 3 November 2017, the tax Administration in Peru issued report no. 039-2017-SUNAT/7T0000, clarifying the exchange rate applicable to capital gains arising from the transfer of shares. The report refers to a transaction as part of which a
See MoreIndia: CBDT publishes guidance on appropriate use of CbC reports
On 27 June 2018, the central board of direct taxes (CBDT) released Instruction No. 02/2018 to provide guidance on the appropriate use of CbC (Country-by-Country reports) reports. In 2015, the Organization for Economic Co-operation and Development
See MorePakistan: FBR extends tax amnesty scheme period to 31 July 2018
On 7 July 2018, the Federal Board of Revenue (FBR) approved an extension in tax amnesty scheme till 31 July 2018. Previously an ordinance was sent to the president of Pakistan for approval of the extension. The deadline for filing amnesty
See MoreIndia: CBDT publishes notification for taxation of foreign company held as resident in India as per POEM
On 22 June 2018, the Central Board of Direct Taxes (CBDT) has issued a final Notification No. 29/2018, dealing with special transitional provisions for a foreign company said to be a resident in India on account of Place of Effective Management
See MoreRussia publishes Order on CbC report automatic exchange
On 26 June 2018, Russia has approved the Order of the Federal Tax Service of 30 May 2018 No. MMV-7-17 / 359 regarding the States and Territories list with which Russia will automatically exchange Country-by-Country (CbC)
See MoreIndia: HC decides on principles for admissibility of transfer pricing appeals
On 25 June 2018, the Karnataka High Court (HC) announced the decision in the case of Softbrands India Private Limited v. DCIT (TS-475-HC-2018(KAR)-TP). The ruling sets forth some significant principles relating to admissibility of appeals by HCs
See MoreWorld Tax Brief: July 2018
Bangladesh Main corporate tax rate: On 28 June 2018, the Parliament passed the national budget for fiscal year 2018-2019. The corporate tax rate has been reduced to 40% from 42.50% for non-publicly traded banks, insurance and financial
See MoreLithuania increases the penalties for tax evasion
On 17 May 2018, the Parliament passed amendments to the tax law, which increase the penalties for tax evasion. Under the amendments, if the tax authorities identify income that the taxpayer cannot justify at the time of inspection, the taxpayer will
See MoreThailand publishes various tax incentives
Thailand issued a series of Royal Decrees on 13 May 2018, which provide for various tax incentives. One of the main incentives is under Royal Decree No. 658, which extends the five-year corporation tax (exemption) for start-ups in certain target
See MoreIndia: CBDT proposes amendments to secondary adjustment rules for transfer pricing
On 20 June 2018, the Central Board of Direct Taxes (CBDT) has announced the publication of a draft notification for amendment in Rule 10CB of the Income-tax Rules, 1962 in respect of computation of interest income pursuant to secondary adjustment
See MoreLuxembourg: Government submits EU Anti-Tax Avoidance Directive (ATAD) to Parliament
On 20 June 2018, the draft law (Draft Law) implementing the European Union (EU) Anti-Tax Avoidance Directive (ATAD) was introduced in the Luxembourg Parliament. Accordingly, as from 2019, a new provision will be introduced that limits interest
See MoreSweden: Tax Authority publishes guidelines on use of CbC report information
On 18 May 2018, the Swedish tax authority issued guidelines, clarifying its use of country-by-country (CbC) report information. The guidelines are in line with the OECD guidelines on the appropriate use of information included in CbC reports that
See MorePakistan enacts Finance Bill 2018
The Finance Bill, 2018 was passed by the government on 22 May 2018, with some amendments. The Bill provides for the implementation of the measures proposed as part of the 2018-2019 Budget. The main measures are summarized as follows: Corporate
See MoreIndia: No international transaction with related party in the absence of an agreement with the AE
Recently, the Mumbai Bench of the Income-tax Appellate Tribunal (the Tribunal) ruled its decision on the transfer pricing (TP) case of Colgate Palmolive (India) Ltd. v. ACIT (ITA No. 6073/Mum/2014 and ITA No. 2778/Mum/2011) in favor of the taxpayer.
See MoreIndia: The expenditure specifically incurred for Indian taxpayers’ market cannot be construed to benefit the AE
On 14 May 2018, the Delhi Bench of the Income-tax Appellate Tribunal ruled its decision on the transfer pricing (TP) case of BMW India Pvt. V. ACIT (ITA No 6160 / Del. / 2014) in favor of the taxpayer. The court held that, expenses that are
See MoreDanish Government adopts the PE rules amendments for pass-through entities
On 9 June 2018 Denmark adopted Law No. 725 of 8 June 2018 provides for amendments to the permanent establishment (PE) rules with respect to investments made in Denmark through transparent entities. The amendment excludes foreign investors making
See MoreDanish Government adopts Law on R&D deductions
On 9 June 2018 Denmark adopted Law on R&D Deductions in the Official Gazette. Law No. 722 of 8 June 2018 provides for an increase in the allowed deduction for R&D from the prior 100% to: 101.5% for the 2018 and 2019 tax years; 103% for
See MoreSweden: Parliament approves draft bill regarding corporate income tax changes
On 14 June 2018, the Swedish Parliament approved the bill introducing new tax rules for the business sector. The bill includes following measures: A reduction in the corporate tax rate from 22% to 21.4% in 2019 and 2020, and to 20.6% from 2021;
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