Japan: Cabinet Approves 2016 Tax Reform Proposal
The Japanese Cabinet approved the 2016 tax reform proposal (2016 Tax Reform) on December 24, 2015. The proposal contains modifications to Japanese transfer pricing (TP) documentation requirements. The modifications are based on recommendations in
See MoreSingapore: Changes to Transfer Pricing Guidelines
The Inland Revenue Authority of Singapore (IRAS) published the third edition of the e-Tax Guide on the transfer pricing guidelines on 4 January 2016. The latest changes are summarized as follows: Amended guidance on the cost-plus method (CPM);
See MoreWorld Tax Brief: December 2015
Australia GAAR: The Tax Laws Amendment (Combating Multinational Tax Avoidance) Bill 2015 received Royal Assent on 11 December 2015. The Bill implements a new anti avoidance rule designed to counter the erosion of the Australian tax base by
See MoreIndia: CBDT issues draft guidelines for determination of a company’s place of effective management
India's Central Board of Direct Taxes (CBDT) has issued draft guiding principles for determining if a company is a resident in India or has its place of effective management in India. The Finance Act 2015 amended the provisions of section 6(3) of
See MoreDenmark: Government Passes bill on Country-by-Country Reporting
On 18 December 2015 the Danish Parliament approved the draft Bill introducing Country-by-Country Reporting based on Action 13 of the Organization for Economic Co-operation and Development (OECD) project on Base Erosion and Profit Shifting
See MoreMexico-Publishes new Income Tax Law regulations regarding corporate taxation
The new regulations to the Income Tax Law were published in the Official Gazette on 8 October 2015. The main changes included in the regulations are summarized below: Corporate taxation: - Informative returns must be filed for donations exceeding
See MoreBrazil: New deadlines for corporate tax e-filing
On 3rd December 2015 Brazil’s tax authority (Receita Federal do Brasil - RFB) announced new deadlines for certain information filings by corporate taxpayers for 2015. The guidance of Instruções Normativas nº 1.594/15 and nº 1.595/2015,
See MoreJapan: 2016 Tax Reform Outline
Japan’s ruling party released the 2016 Tax Reform outline on 16 December 2015. The Outline includes a further corporate tax rate reduction and introduction of a new transfer pricing documentation rule. A tax reform bill will be prepared based on
See MoreWorld Tax Brief: November 2015
Spain Main Corporate tax rate: The corporate income tax rate will be reduced from 28% to 25% from January 2016. Following Companies also are not required to file tax returns for taxable periods commencing on or after 1 January 2016 if: i) their
See MoreLithuania: Changes to various tax laws
Draft amendments to various tax laws were approved by the parliament in the first reading on 17 November 2015. If adopted by the parliament in the final reading, the amendments will enter into force from January 2016. The modifications are
See MoreDTA between Japan and Taiwan signed
Japan and Taiwan signed a double taxation agreement (DTA) in Tokyo on 26 November 2015. This DTA is the first agreement regarding taxes between Japan and Taiwan. The agreement provides for a withholding tax rate of 10% on payments of dividends,
See MoreEgypt: Clarification guideline with respect to corporate taxation
The Egyptian Tax Authority published Guideline No. 28 for 2015 on 12 November 2015. The Guideline clarifies certain issues with respect to changes introduced by Decree Law No. 96 for 2015 which amended Income Tax Law No. 91 for 2005. The most
See MoreSlovenia: Changes to Corporate Income Tax Law
The Ministry of Finance proposed amendments to the Corporate Income Tax Law on 10 November 2015. Once adopted by the Slovenian parliament the amendments will apply from 1 January 2016. The following amendments are proposed: Decrease of tax
See MoreIndia: Government Press Release on phasing out the plan of deductions under the Income-tax Act
The Finance Minister in his Budget Speech for 2015 indicated that the rate of corporate tax will be reduced from 30% to 25% over the next four years along with the corresponding phasing out of exemptions and deductions. The Central Board of Direct
See MoreProtocol to a treaty between Russia and Singapore signed
Russia and Singapore signed an amending protocol to the Russia - Singapore Income Tax Treaty (2002) on 17 November 2015, in Moscow. Further details will be reported
See MoreIndia: A taxpayer is entitled to foreign tax credit against the MAT liability
Recently, the Bangalore Bench of the Income-tax Appellate Tribunal (the Tribunal) in the case of: DCIT v. Subex Technology Ltd. [ITA No.913 (B) /2013, the court held that, credit for tax paid in a foreign country would be available under Section 90
See MoreIndia: Progressive Refund Process, Exports of services
In India Exporters of services are now entitled to claim a refund of the unused central value added tax credit of service tax / duties paid with respect to the procurement of goods and services that are used for the export of output
See MoreIndia: No Transfer pricing adjustment when tax avoidance not possible
The Mumbai Bench of the Income-tax Appellate Tribunal in the case of: DCIT v. Tata Consultancy Services Ltd. (ITA no. 7513/2010), held that an Assessing Officer cannot “mechanically” refer a taxpayer’s international transaction to a Transfer
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