World Tax Brief: August 2016
UK Incentives: On 20 July 2016 the UK publishes updated statistics on claims for creative industry tax relief. The statistics include data for the film tax relief, high-end television tax relief, animation tax relief and video games tax relief
See MoreDenmark: Danish Assessment Board issues ruling on profit allocation to permanent establishment
The Danish Assessment Board gave its ruling on 16 August 2016, in the case of SKM2016.353.SR on the correct profit allocation to a permanent establishment (PE) in the form of a construction company. Facts of the case: The taxpayer is a foreign
See MoreMauritius: Publishes Budget for 2016-2017
The budget for 2016 - 2017 was provided on 29 July 2016 to the National Assembly by the Minister of Finance and Economic Development. The main proposals of the Budget on income taxes are summarized below: -Tax holidays for companies holding licences
See MorePakistan: Changes capital gains tax and immovable property
The President of Pakistan has circulated the Income Tax (Amendment) Ordinance, 2016 to further amend the provisions regarding valuation of immovable properties under the Income Tax Ordinance 2001 (the Ordinance). Main features of the Amendment
See MoreSweden: Transfer pricing guidance updated with BEPS
The tax authorities issued an updated version of the Swedish Transfer Pricing guidance on July 2, 2016. The guidance has been updated with the final report on aligning Transfer Pricing outcomes with value creation (Actions 8-10) of the Action Plan
See MorePakistan: Government has decides to apply 0% sales tax on five export sectors
The government has decided to zero-rate for the local suppliers of textile, leather, carpets, surgical and sports sectors from 2016-17. According to the meeting between textile sector and Finance Minister, Five Export Sectors'' Associations,
See MoreIndia: The tribunal held the Comparable Uncontrolled Price is the most appropriate method
The Delhi Bench of the Income-tax Appellate Tribunal upheld the decision in the case of: Liugong India Private Ltd. v. ACIT (ITA No. 1482/Del/2015) and decided that when comparable are available, the CUP method is the best method to use in
See MoreWTO backs Argentina’s anti-avoidance tax measures
The Appellate Body of the World Trade Organization (WTO) provided its report on 14 April 2016, regarding "Argentina – Measures relating to trade in goods and services" case brought by Panama. In the case concerned, and in relation to Argentina's
See MoreWorld Tax Brief: July 2016
Argentina Dividend: In Argentina, Law 27,260, the amendment to the Income Tax Law (LIG) was publishes in the Official Gazette. According to the amendment Law 27,260 abolished the 10% withholding tax established by article 90 LIG which was applied
See MoreAustria: Publishes government bill of new Transfer Pricing Documentation Law
Finance (MoF) published the government bill of the European Union (EU) Tax Amendment Act 2016, including among other provisions, the new Austrian Transfer Pricing Documentation Law (TPDL). This follows the publication of the draft TPDL on 9 May 2016
See MoreIndia: Tribunal held that Transfer Pricing Officers have the authority to determine the arm’s length price
The Delhi Bench of the Income-tax Appellate Tribunal in the case of: Nikon India Pvt. Ltd. v. DCIT (ITA No. 6314/Del/2015), held that Transfer Pricing Officers have the authority to determine the arm’s length price of any international transaction
See MoreIndia: CBDT amends rules relating to GAAR effective date
The Central Board of Direct Taxes (CBDT) issued Notification No. 49/2016 (the Notification) dated 22 June 2016 on the effective date of the general anti-avoidance rules (GAAR). According to the Notification, the amendments to the Income Tax Rules,
See MoreSlovenia: Publishes proposal for amending corporate income tax
The government published a proposal on 12 of July 2016, for amending the Corporate Income Tax Law. According to the proposal, the corporate income tax rate will be increased to 19% from 17% and which is effective from 1 January 2017. Similarly, the
See MoreJapan: Publishes guidance under new transfer pricing documentation rules
Japan's national tax agency has released guidance concerning new transfer pricing documentation rules. The guidance released on 30 June 2016 and under Japan's 2016 tax reform, amendments were made to the Japanese transfer pricing documentation
See MoreSlovenia: Publishes R&D tax incentives guidance
The Financial Administration published the guidance on the application of research and development (R&D) tax incentives on 14 July 2016. According to the guidance, companies may claim a 100% corporate income tax base reduction for qualifying
See MoreTaiwan : Implements CFC, place of effective management concepts
Taiwan’s Legislative Yuan amended the Income Tax Act (ITA) on 12 July 2016, and introduced the controlled foreign company (CFC) rules, incorporating some of the recommendations provided in the Organization for Economic Co-operation and
See MoreSingapore: Publishes E-Tax Guide on General anti-avoidance rule
The Inland Revenue Authority of Singapore (IRAS) issued an e-Tax Guide (the Guide) on 11 July 2016, clarifying the general anti-avoidance rule and its application. IRAS issues the Guide with the following purposes: -To explain IRAS's approach to
See MoreEl Salvador: Financial statements need to be submitted electronically by large taxpayers
The tax authorities issued Circular DG-001/2016 on 13 June 2016, launching that large taxpayers must file their 2015 financial statements together with the notes and tax report electronically using digital Form F-457 through the Ministry of
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