Monthly Briefs

Tax Treaty News: May 2017

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Armenia and Sweden On 1 June 2017, the Double Taxation Agreement (DTA) between Armenia and Sweden for the avoidance of double taxation and the prevention of fiscal evasion with respect to taxes on income entered into force. This Agreement will apply from 1 January 2018.
Switzerland and Kosovo On 26 May 2017, Switzerland and Kosovo signed a Double Taxation Agreement (DTA) in the area of taxes on income and capital, in Pristina. The agreement will ensure legal certainty and a contractual framework that will have a beneficial impact on the two states’ economic relations.
Morocco and Bahrain On 25 May 2017, the Council of government of Morocco approved the amending protocol of Double Taxation Agreement (DTA) with Bahrain.
Brazil and Russia On 24 May 2017, the Senate of Brazil approved the Double Taxation Agreement (DTA) with Russia.
Brazil and India On 24 May 2017, the Senate of Brazil approved the amending protocol of Double Taxation Agreement (DTA) with India.
Bahrain and Philippines On 22 May 2017, the Council of Ministers of Bahrain approved the amending protocol of Double Taxation Agreement (DTA) with Philippines.
Cyprus and San Marino On 19 May 2017, the protocol amending the agreement between Cyprus and San Marino for the Avoidance of Double Taxation with respect to Taxes on Income was signed, in Nicosia. The Protocol was signed, on behalf of the Republic of Cyprus, by the Minister of Foreign Affairs, Mr Ioannis Kasoulides, and on behalf of the Republic of San Marino, by the Minister of Foreign Affairs of the country, Mr Nicola Renzi.
Kazakhstan and Uzbekistan On 18 May 2017, Mr. Shavkat Mirziyoyev, the President of Uzbekistan signed a Decree PP-2971 ratifying the amending protocol of Double Taxation Agreement (DTA) with Kazakhstan.
Germany and Turkmenistan On 12 May 2017, the Federal Council of Germany approved the Double Taxation Agreement (DTA) with Turkmenistan. Once in force and effective, the new treaty will replace the existing DTA of 1981.
Belgium and Russia On 11 May 2017, the Belgian parliament approved the Double Taxation Agreement (DTA) with Russia. Once in force and effective, the new treaty will replace the existing DTA of 1995.
Mexico and Spain On 11 May 2017, the lower house of parliament of Spain approved the amending protocol of Double Taxation Agreement (DTA) with Mexico.
Cyprus and Luxembourg On 8 May 2017 a Double Taxation Agreement (DTA) between Cyprus and Luxembourg was signed in Nicosia.
Romania and Uzbekistan On 8 May 2017, the president of Romania signed a law ratifying the amending protocol of Double Taxation Agreement (DTA) with Uzbekistan.
Romania and China On 8 May 2017, Mr. Klaus Iohannis, the president of Romania signed a law ratifying the Double Taxation Agreement (DTA) with China. Once in force and effective, the treaty will replace the existing DTA of 1991.
Italy and Romania On 4 May 2017, the Senate of Italy approved the draft law ratifying the Double Taxation Agreement (DTA) with Romania. Once in force and effective, the treaty will replace the existing DTA of 1977.
Bosnia and Herzegovina and Romania On 4 May 2017, the upper house of parliament of Bosnia and Herzegovina approved the Double Taxation Agreement (DTA) with Romania. Once in force and effective, the treaty will replace the existing DTA of 1986.
Morocco and South Sudan On 4 May 2017, the Moroccan Council of government approved the Double Taxation Agreement (DTA) with South Sudan.
Morocco and Rwanda On 4 May 2017, the Moroccan Council of government approved the Double Taxation Agreement (DTA) with Rwanda.
Morocco and Madagascar On 4 May 2017, the Moroccan Council of government approved the Double Taxation Agreement (DTA) with Madagascar.
Morocco and Ghana On 4 May 2017, the Moroccan Council of government approved the Double Taxation Agreement (DTA) with Ghana.
Morocco and Ethiopia On 4 May 2017, the Moroccan Council of government approved the Double Taxation Agreement (DTA) with Ethiopia.
Belarus and Pakistan On 3 May 2017, Belarus ratified the amending protocol to the Double Taxation Agreement (DTA) with Pakistan.
Belarus and Hong Kong On 3 May 2017, Belarus ratified the Double Taxation Agreement (DTA) with Hong Kong for the avoidance of double taxation and the prevention of fiscal evasion with respect to taxes on income.
Barbados and Cyprus On 3 May 2017 a Double Taxation Agreement (DTA) between Barbados and Cyprus was signed. The agreement provides for the avoidance of double taxation and the prevention of fiscal evasion with respect to taxes on income.
Italy and Barbados On 2 May 2017, the Chamber of Deputies of Italy approved the draft law ratifying the Double Taxation Agreement (DTA) with Barbados for the avoidance of double taxation and the prevention of fiscal evasion with respect to taxes on income.
Egypt and Saudi Arabia On 1 May 2017, the cabinet of Saudi Arabian approved the Double Taxation Agreement (DTA) with Egypt for the avoidance of double taxation and the prevention of fiscal evasion with respect to taxes on income.
Ukraine and Malta On 1 May 2017, the President of Ukraine signed a law ratifying the Double Taxation Agreement (DTA) with Malta for the avoidance of double taxation and the prevention of fiscal evasion with respect to taxes on income.
Qatar and Spain On 28 April 2017, the lower house of parliament of Spain approved the Double Taxation Agreement (DTA) with Qatar.
Mexico and Spain On 26 April 2017, the Senate of Mexico approved the amending protocol of Double Taxation Agreement (DTA) with Spain.
Mexico and Argentina On 26 April 2017, the Mexican Senate approved the Double Taxation Agreement (DTA) with Argentina for the avoidance of double taxation and the prevention of fiscal evasion with respect to taxes on income.
Finland and Germany On 25 April 2017, Germany ratified the Double Taxation Agreement (DTA) with Finland. Once in force and effective, the new treaty will replace the existing DTA of 1979.
Belarus and Pakistan On 21 April 2017, the Council of the Republic of Belarus approved the amending protocol of Double Taxation Agreement (DTA) with Pakistan.
Belarus and Hong Kong On 21 April 2017, the Council of the Republic of Belarus approved the Double Taxation Agreement (DTA) with Hong Kong for the avoidance of double taxation and the prevention of fiscal evasion with respect to taxes on income.
Ukraine and Luxembourg On 18 April 2017, the amending protocol of Double Taxation Agreement (DTA) between Luxembourg and Ukraine entered into force. The amending protocol and Agreement will apply from 1 January 2018.
Ethiopia and Portugal On 9 April 2017 the Double Taxation Agreement (DTA) between Ethiopia and Portugal entered into force. The agreement provides for the avoidance of double taxation and the prevention of fiscal evasion with respect to taxes on income.

Transfer Pricing Brief: May 2017

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Italy: Requirement-Rule: According to Decree No.50 published on 24 April 2017, the definition of normal value with the concept of arm’s length will be modified to be more aligned with Organisation for Economic Co-operation and Development (OECD) principles.
Adjustments-Corresponding adjustment: According to Decree No.50 published on 24 April 2017, corresponding adjustments are now allowed the conclusion of tax audits performed under international cooperation procedures, where the results are agreed by the tax authorities involved.
Special Areas-Intangible property: The Italian patent box regime allows taxpayers to elect to exclude a percentage of the income derived from the use and/or the transfer of ownership of relevant intangibles from the tax base declared for both corporate income tax (IRES) and regional tax (IRAP) purposes.
See the story in Regfollower
Croatia: CbC reporting requirement-General rule: The country by country reporting requirement applies to MNEs headquartered in Croatia with annual consolidated group revenue equal to or exceeding €750 million in the previous year. CbCR applies for fiscal years beginning on or after 1 January 2016.
CbC reporting requirement-Parent company: The CbCR is filed by the ultimate parent of those multinational groups (“MNG”) that have total consolidated revenues of EUR 750 million or more in the last financial year.
CbC reporting requirement-Definition of group: The country by country reporting requirement applies where the consolidated group revenue in the preceding year is at least EUR 750 million.
CbC reporting requirement-Timing: The first CbC report for the fiscal year started on or after 1 January 2016 must be by an ultimate parent entity of the MNE group or its surrogate parent entity that is resident in Croatia within 12 months from the last day of that tax year. Thus, for the fiscal year that ended on December 31 2016, the deadline is December 31 2017.
CbC reporting requirement-Penalty for documentation failure: Penalties ranging between HRK 2,000 to HRK 200,000 will apply for noncompliance.
See the story in Regfollower
Availability of APA: The Guidance on Advance Pricing Agreements (APAs) has been published in Official Gazette No. 47/15 on 3 May 2017. Accordingly, APAs could be concluded in respect of the transfer pricing treatment of intercompany transactions and would be binding on the TA.
Authority: Tax Administration.
Rules: APAs could be concluded in respect of the transfer pricing treatment of intercompany transactions and would be binding on the TA. Before submitting an official request, the taxpayer may also initiate a non-binding consultation procedure with the TA discussing the transfer pricing treatment of the intercompany transaction for which the APA request will be filed.
Withdrawal: APAs can be canceled if factual circumstances change; legislation has been amended or annulled; and facts have not been truthfully presented to the TA.
Validity: 5 years.
Fees: Ranges from HRK 15,000 to HRK 50,000 depending on the taxpayer’s turnover as stated in the most recent tax return.
See the story in Regfollower
Pakistan: Dispute resolution-Alternative dispute resolution: The Federal Board of Revenue (FBR) has released a guide on the mechanism of ADR in April 2017. Based on the guide, taxpayers can seek to resolve tax disputes via ADR instead of the conventional method of appealing through the appellate authorities, tribunals and courts of law. The aim of the ADR is to reduce the costs of appeal to taxpayers and to expedite the resolution of tax disputes.
See the story in Regfollower
Norway: Financial services-Restriction on interest deduction: On 4 May 2017, a discussion paper that proposes changes to the earnings stripping rules has been issued by the Norwegian Ministry of Finance which further extends the limitation to also include interest costs on unrelated party debt.  The new proposed rules provide for one exception according to which the taxpayers are able to document that the equity ratio of the company is not lower than the equity ratio reported in the consolidated financial statements, full interest costs on unrelated party debt will continue to be deductible. If passed, the amendment would be effective from 1 January 2018.
See the story in Regfollower
Iceland: CbC reporting requirement-General rule: According to Regulation no.245/2017, Country-by-Country Reporting shall include the applicable information on an aggregate basis for all entities within each country. In the previous regulation no. 1166/2016, this information was requested for each entity instead of collectively for each country.
BEPS related compliance-Timing: According to Regulation no.245/2017, Country-by-Country reporting must be filed with the Directorate of Internal Revenue before the end of each calendar year or by the end of financial year. In the previous regulation no. 1166/2016, CbCR was to be filed no later than 12 months after the close of the group’s financial year.
See the story in Regfollower
Korea: BEPS related compliance-Master file: A Master file must be submitted for fiscal years beginning on or after 1 January 2016, by all domestic corporations and foreign corporations with Korea-source income with Sales revenue exceeds KRW 100 billion (approximately U.S. $89 million) and the volume of cross-border related-party transactions exceeds KRW 50 billion (approximately U.S. $44.4 million)
BEPS related compliance-Local file: A Local file must be submitted for fiscal years beginning on or after 1 January 2016, by all domestic corporations and foreign corporations with Korea-source income with Sales revenue exceeds KRW 100 billion (approximately U.S. $89 million) and the volume of cross-border related-party transactions exceeds KRW 50 billion (approximately U.S. $44.4 million).
BEPS related compliance-CbC reporting requirement: The CbC report is required to be submitted by ultimate parent company when the earlier year’s consolidated sales revenue exceeds KRW 1 trillion.
Financial services-general rule: The tax authority updated the rules on the arm’s length interest rate applicable for loan transactions between a resident and a foreign related-party. The new rules set forth the arm’s length interest rate for lending and borrowing involving a Korean resident taxpayer to a foreign related party.
See the story in Regfollower
India: BEPS related compliance-CbC reporting requirement: India has introduced a country-by-country (CbC) reporting requirement in section 286 of the Indian Income-tax Act-1961, with effect from financial year 2016-2017. The first round of CbC reports, when applicable, will have to be filed with the Indian tax authorities by 30 November 2017.
See the story in Regfollower
Information exchange-Bilateral: On May 17, 2017, Indian Union Cabinet has given its approval for signing of a multilateral convention to implement tax treaty-related measures to prevent base erosion and profit shifting (BEPS).
Information exchange-Multilateral: The Union Cabinet has given its approval for India’s signing of a multilateral convention(MLI) to implement tax treaty-related measures to prevent base erosion and profit shifting (BEPS) which is scheduled to take place in Paris on 7 June 2017.
See the story in Regfollower
Australia: Risk Assessment: Draft Practical Compliance Guideline PCG 2017/D4 of 16 May 2017, sets out a self-assessment risk framework which will allow taxpayers to self-assess the tax risk of their related party financing arrangement and realize the compliance approach the Commissioner is likely to implement based on the risk profile. The provisions of the draft guidance will apply to both inbound and outbound financing arrangements that are entered into with a non- resident related party.
See the story in Regfollower
Main corporate income tax rate: In the 2016–17 Budget, the Government announced that it intended to progressively reduce the corporate tax rate from 30 per cent to 25 per cent over the next ten years. The corporate tax rate is reduced from 28.5% to 27.5% for the 2016–17 income year for small business entities.
See the story in Regfollower
Hungary: CbC reporting requirement-General rule: Hungary released a draft law on country-by-country (CbC) reporting on 10 March 2017. According to law, all Hungarian tax resident entities that are part of a multinational group that derives annual consolidated income of at least EUR 750 million will need to comply with the CbC reporting requirements.
Parent company: A Hungarian resident ultimate parent entity must file a country-by-country report with the Hungarian tax authority within 12 months of the last day of its reporting fiscal year. If the ultimate parent is tax not resident in Hungary, Hungarian resident constituent entities may become reporting entities and may be appointed by their groups to file the CbC report.
Definition of group: Global group means a group of entities, at least one of which is a foreign entity that are consolidated for accounting purposes as a single group.
Profits and tax paid: The CBCR must include information on the main data of the MNE per each tax jurisdiction involved with its operation i.e. revenue, pre-tax profit / loss, paid corporate income tax, capital etc.
Employees: The average number of employees in each entity must be reported.
Assets: CbC reports must contain tangible assets other than cash or cash equivalents and main business activity.
Timing: The first CbC reports and notifications must be filed for the fiscal year commencing on or after 1 January 2016, within 12 months of the last day of that fiscal year. In future fiscal years notifications must be made no later than the last day of the reporting fiscal year. Any change must be reported within 30 days of such change occurring.
Penalty for non-compliance: Failing to submit reports or notifications, late submission, or providing incorrect, false or incomplete information may be subject to a default penalty of up to HUF 20 million.
See the story in Regfollower
Czech Republic: Information exchange-Multilateral: The government of the Czech Republic has given its approval of signing of the multilateral convention (MLI) to implement tax treaty-related measures to prevent base erosion and profit shifting (BEPS) which is scheduled to take place in Paris on 7 June 2017.
See the story in Regfollower
Singapore: Cost-plus method: Recently, the Inland Revenue of Singapore has clarified its practice that allows services companies which provide “routine support services” to adopt the cost-plus mark-up method.
See the story in Regfollower
France: CbC reporting requirement-Parent company: If the parent company established in France and files the CbC report that entity must “check a box” indicating this information on its tax return. If a legal entity established in France is the subsidiary of an ultimate parent company located in a jurisdiction and files the CbC report that entity is not required to mention any CbC reporting information on its tax return. Other than the above circumstances entity must indicate the legal name and address of the entity filing the CbC report on its income tax return.
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Colombia: Local file: Local files must be filed for tax year 2016 between 11 July and 25 July, depending on the last number of the taxpayer’s ID, as established in Decree 1625 of 2016.
Master file: Must be filed for tax year 2017 in 2018 in accordance with dates to be determined by the Government; tax year 2016 is not subject to the master file requirement.
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Germany: Information exchange-Multilateral: On 21 December 2016, the Federal Government approved the signing of the Multilateral Convention on the implementation of tax-related measures to prevent the shortening of profits and the shift of profit. The signing ceremony is scheduled to take place in Paris on 7 June 2017.
See the story in Regfollower
Russia: Information exchange-Multilateral: The Russian government approved the signing of the, Multilateral Convention (2016) (MLI). The signing ceremony is scheduled to take place in Paris on 7 June 2017.
See the story in Regfollower
Ukraine: APAs-Rules: According to the adopted amendments to the Regulation No. 504 of 17 July 2015, an APA will become effective on the date agreed by the State Fiscal Service and a taxpayer (depending on the terms and conditions of the controlled transactions) or on 1 January of the year following that in which the APA was signed.
APAs-Validity: According to adopted amendments to the Regulation No. 504 of 17 July 2015, the validity of an APA is extended from 3 to 5 years.
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Brazil: BEPS related compliance-CbC reporting requirement-General rule: According to Normative Instruction 1,709/2017 published on May 25 2017, the Brazilian entity may amend its corporate income tax return within 60 days and file the CbC report on behalf of the entire group for calendar year 2016 if a competent authority agreement (CAA) is not concluded between Brazil and the reporting entity’s jurisdiction by 31 December 2017.
See the story in Regfollower
Belgium: Master file: Belgium’s Federal Public Service (FPS) Finance recently updated its transfer pricing documentation forms in relation to master file based on BEPS Action 13.
CbC reporting requirement-Timing: On December 22, 2016, the Federal Public Service (FPS) announced the extension of CbC reporting notifications to September 30, 2017 for fiscal year 2016.
See the story in Regfollower
Bulgaria: Information exchange-Multilateral: The Bulgarian government approved the signing of the, Multilateral Convention (2016) (MLI) on 17 May 2017. The signing ceremony is scheduled to take place in Paris on 7 June 2017.
See the story in Regfollower
Israel: Information exchange-Multilateral: On 22 May 2017, the tax authority in Israel announced the signing of a multilateral agreement for the automatic exchange of country-by-country (CbC) reports and of common reporting standard (CRS) information.
See the story in Regfollower
Spain: Specific TP compliance: Spain’s Tax Agency has published a draft order approving Form 232 for reporting related-party transactions and transactions and situations that involve countries and territories considered to be tax havens. The deadline for filing Form 232 has been set generally in May.
See the story in Regfollower

World Tax Brief: May 2017

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Australia Corporate tax rate: The 2017-18 federal budget has been delivered on 9 May 2017 and the government announced a reduction in the small business tax rate from 28.5% to 27.5% for the 2016–17 income year. The turnover threshold to qualify for the lower rate will start at $10 million (in 2016-17) and progressively rise until the 27.5% rate applies to corporate tax entities with less than $50 million aggregated annual turnover in the 2018-19 income year. From 2017-18, entities eligible for the lower tax rate will be known as base rate entities.
Capital gains tax: The Budget for 2017 -18 also proposes the changes to the foreign resident capital gains withholding (FRCGW) rate and threshold. The changes will apply to contracts entered into on or after 1 July 2017, for real property disposals where the contract price is $750,000 and above (currently $2 million) and the FRCGW withholding tax rate will be 12.5% (currently 10%).
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Central management and control: Recently, the Australian Tax Office has released a new draft ruling TR 2017/D2 and has withdrawn its preceding Ruling TR 2004/15 on the tax residence of foreign incorporated companies. Accordingly, if a company carries on business and has its central management and control in Australia, it will necessarily carry on business in Australia. That is so even when the only business carried on in Australia consists of that central management and control, and its trading operations are conducted outside Australia.
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Canada Incentives: The Canadian government has proposed to extend the small deduction to certain farmers. The small business deduction effectively reduces corporation tax from 15 percent to 10.5 percent on the first CAD500, 000 (USD365, 281) of active business income generated by a Canadian-controlled private company.
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France Dividends/Profits Distributions: The Court of Justice of the European Union (CJEU) issued a judgment on 17 May 2017, ruling that the 3% contribution on distributed profits is not compatible with article 4-1 of the European Union (EU) Parent-Subsidiary Directive (PSD) when the parent company makes the redistribution of the dividends received from its subsidiaries.
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Corporate tax rate: French newly elected president has committed to reducing the corporate tax rate from current rate of 33.3% to 25% with the aim to bring it in line with the EU average within five years.
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Italy Incentives: The Italian revenue on 9 March 2017 provided tax instruction, the clarification of the Italian patent fund regimes, the tax credit for research and development activities (R & D) and the tax credit for new operating assets.
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Singapore Incentives: Singapore has released Budget for 2017 on 20 February 2017, for the financial year 1 April 2017 to 31 March 2018. The Budget bill raised the existing corporate income tax (CIT) rebate cap from SGD 20,000 to SGD 25,000 for the assessment year 2017, but the rebate rate remains unchanged at 50% of tax payable. This CIT rebate will be extended for another year to YA 2018 but there will be a reduced rate of 20% of tax payable with a cap of SGD 10,000.
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Kenya Incentives: The Finance Bill, 2017 published on 3rd April 2017 which was announced on 30th March 2017. The Bill has amended various tax provisions while at the same time providing clarity on the existing provisions. As a result, A 150% investment deduction allowance has been introduced for capital expenditure in the economy; 100% investment deduction on capital expenditure added on the construction of a building or machine installation by or for use in the Special Economic Zone. This is aimed at encouraging investment at the SEZs; To encourage investment and the assembly of motor vehicles in Kenya the corporate tax rate is to be reduced from 30% to 15% for the first 5 year for new assemblers who assembling motor vehicles locally; A 150% deduction incentive will be applicable to the fishing sector; A 100% investment deduction will be applied to the special economic zone on buildings and machinery.
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India Dividend distribution tax: The Supreme Court of India in the case of: Godrej & Boyce Manufacturing Company Limited v. DCIT (Civil Appeal No. 7020 of 2011), held that disallowance under Section 14A of the Income-tax Act, 1961 (the Act) would apply to dividend income which is subject to dividend distribution tax (DDT).
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Computation of taxable income: The Supreme Court of India in the case of:  Raj Dadarkar and Associates v. ACIT (Civil Appeal No. 6455-6460 OF 2017), held that the income from the sub-licensing of the property is taxable as house property income and not business income.
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Hong Kong Incentives: Hong Kong introduced new tax rules for aircraft leasing industry to foster the proposed development of Hong Kong as an aircraft leasing centre.
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Czech Republic Withholding tax on interest: The Czech Republic introduces new withholding tax requirements which contain the withholding tax provisions. The changes will take effect on the 15th day of their publication. There is a reference to the publication date and is July 1, 2017. The new provisions of the withholding tax are in principle for shareholders’ associations and profit-sharing companies and financial institutions that pay interest on these companies. The changes extend the chance of 19% withholding tax on interest on deposits. This new measure requires additional requirements for banks and savings banks and credit institutions.
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Norway Participation relief: The tax authorities released a binding advance ruling on 4 May 2017, regarding the application of a domestic exemption from dividends to an Irish holding company. The judgment provides that the dividends paid by the Norwegian company to the Irish holding company are exempt from Norwegian withholding tax under the domestic exemption from Norway. To be qualified for the withholding tax exemption, the dividend recipient must be practically identical to certain non-individual assessable person according to the Norwegian Tax Act.
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Malaysia Sanctions for non-compliance:  The Inland Revenue Board of Malaysia (IRB) has proposed to increase the rate of penalty to 100% on tax payable on undeclared or under-declared income beginning with effect from 1 January 2018.
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Audits: On 1 May 2017, the Inland Revenue Board of Malaysia (IRBM) adopted a modified Tax Examination Board. The aim of the revised framework is to ensure that tax audits are conducted fairly, transparently and impartially. The framework outlines the rights and obligations of audit officers, taxpayers and taxpayers in relation to a tax audit. In addition, the objective of the framework is to assist the auditors in carrying out their tasks efficiently and effectively and to assist taxpayers in fulfilling their obligations.
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Hungary Tax Rate: The Hungarian Parliament has approved an increase in the country’s advertising tax. The new legislation will increase advertising revenues from 5.3% to 7.5% as from 1 July 2017.
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South Africa Tax compliance: On 15 May 2017, the South African Revenue Service (SARS) has introduced important changes and improvements to its current dispute settlement process as part of the ongoing commitment to providing a better service to taxpayers. For the first time, SARS has implemented an electronic requirement for reasons via eFiling or SARS branches. The Request for Reasons functionality allows taxpayers to request reasons for an assessment where the grounds provided in the assessment do not sufficiently enable a taxpayer to understand the basis of the assessment and to formulate an objection if the taxpayer is aggrieved by the assessment.
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Nigeria Late payments of tax due: The Finance Minister on 22 May 2017, announced that 5% increased interest charge would impose from 1st of July 2017 on firms that fail to fulfil their tax obligations as and when due as part of measures to sanction tax defaulters and enhance voluntary compliance on tax obligation.
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Greece Tax payment procedure: The Parliament of Greece has adopted a draft bill on 11th of April 2017, which contains some amendments to income tax code. Accordingly, the corporate income tax payment needs to be completed by six instalments instead of eight. Note that, the first instalment needs to be paid on the last working day of the month following the filing deadline and the rest of five instalments must be paid by the last working day of the following five months. The first payment shouldn’t be paid during filing of the corporate tax return.
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Poland Incentives: Government has published an amended draft bill regarding the R&D tax relief. The bill proposes an increase of current income tax deduction from 50% and 30% to 100% depends on the category of eligible costs and the size of the taxpayer. This means that all taxpayers who benefited from the R & D tax exemption are able to save in the income tax PLN 19 to each PLN 100 of qualified costs from 2018 onwards. R&D Tax Relief will come into force on 1 January 2018.
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Netherlands Withholding tax on dividend: On 16 May 2017, the Dutch Government published a public consultation on the previously announced legislative proposals on amendments to the dividend withholding tax rules for holding cooperatives. The Dutch government expects the new amendments to the Dutch Dividend Tax Act (DWTA) to enter into force on 1 January 2018.
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Saudi Arabia Corporate tax rate: The Government of Saudi Arabia has set a range of income tax rates for producers of oil and hydrocarbons, through a royal decree on 27 March 2017. According to the decree, the tax rate for investments exceeding 375 billion riyals ($99.96 billion) will be 50% and the rates will increase for producers with smaller investments.
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UK Facilitation of tax evasion: The United Kingdom adopts a new criminal offence for non-compliance with tax evasion. The Criminal Code, which contains the offences, received royal approval on 27 April 2017 and was due to enter into force in September 2017.
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US Incentives: The IRS has announced that from now “eligible small business start-ups” can elect to apply part or all of their research credit against their payroll tax liability instead of having to apply for the research credit against their income tax liability.
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United States: ADD/CVD Roundup for May 2017

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Following table shows the Federal Register notices related to ADD/CVD cases for May 2017 in United States.

Country Product Investigations Case Number Details
Argentina Biodiesel Determinations C-357-821 See the Federal Register notification
Argentina Biodiesel Determinations A-357-820 See the Federal Register notification
Australia Silicon Metal Postponement of Preliminary Determinations of Countervailing Duty Investigations C-602-811 See the Federal Register notification
Austria Certain Carbon and Alloy Steel Cut-To-Length Plate Antidumping Duty Orders A-433-812 See the Federal Register notification
Austria Carbon and Alloy Steel Cut-to-Length Plate Determinations A-433-812 See the Federal Register notification
Belarus Carbon and Certain Alloy Steel Wire Rod Determinations A-822-806 See the Federal Register notification
Belgium Certain Carbon and Alloy Steel Cut-To-Length Plate Antidumping Duty Orders A-423-812 See the Federal Register notification
Belgium Carbon and Alloy Steel Cut-to-Length Plate Determinations A-423-812 See the Federal Register notification
Belgium Stainless Steel Plate in Coil Antidumping Duty Order, Finding, or Suspended Investigation; Opportunity To Request Administrative Review A-423-808 See the Federal Register notification
Brazil Frozen Warmwater Shrimp Determinations A-351-838 See the Federal Register notification
Brazil Silicon Metal Postponement of Preliminary Determinations of Countervailing Duty Investigations C-351-851 See the Federal Register notification
Brazil Certain Uncoated Paper Initiation of Antidumping Duty Administrative Reviews A-351-842 See the Federal Register notification
Brazil Circular Welded Non-Alloy Steel Pipe Antidumping Duty Order, Finding, or Suspended Investigation; Advance Notification of Sunset Reviews A-351-809 See the Federal Register notification
Brazil Iron Construction Castings Antidumping Duty Order, Finding, or Suspended Investigation; Opportunity To Request Administrative Review A-351-503 See the Federal Register notification
Brazil Iron Construction Castings Countervailing Duty Order, Finding, or Suspended Investigation; Opportunity To Request Administrative Review C-351-504 See the Federal Register notification
Canada 100- to 150-Seat Large Civil Aircraft Initiation of Less-Than-Fair-Value Investigation A-122-859 See the Federal Register notification
Canada 100- to 150-Seat Large Civil Aircraft Initiation of Countervailing Duty Investigation C-122-860 See the Federal Register notification
Canada 100- to 150-Seat Large Civil Aircraft Institution of Antidumping Duty Investigations and Scheduling of Preliminary Phase Investigations A-122-859 See the Federal Register notification
Canada 100- to 150-Seat Large Civil Aircraft Institution of Countervailing Duty Investigations and Scheduling of Preliminary Phase Investigations C-122-860 See the Federal Register notification
Canada Citric Acid and Citrate Salt Antidumping Duty Order, Finding, or Suspended Investigation; Opportunity To Request Administrative Review A-122-853 See the Federal Register notification
Canada Polyethylene Terephthalate Resin Antidumping Duty Order, Finding, or Suspended Investigation; Opportunity To Request Administrative Review A-122-855 See the Federal Register notification
China (PRC) Multilayered Wood Flooring Notice of Correction to the Final Results of Countervailing Duty Administrative Review; 2014 C-570-971 See the Federal Register notification
China (PRC) Malleable Cast Iron Pipe Fittings Notice of Rescission of the Antidumping Duty Administrative Review; 2015-2016 A-570-881 See the Federal Register notification
China (PRC) Certain Cased Pencils Final Results of Antidumping Duty Administrative Review; 2014-2015 A-570-827 See the Federal Register notification
China (PRC) Certain Helical Spring Lock Washers Continuation of Antidumping Duty Orders A-570-822 See the Federal Register notification
China (PRC) Frozen Warmwater Shrimp Determinations A-570-893 See the Federal Register notification
China (PRC) Certain Frozen Warmwater Shrimp Rescission of Antidumping Duty Administrative Review; 2016-2017 A-570-893 See the Federal Register notification
China (PRC) Certain Carbon and Alloy Steel Cut-to-Length Plate Initiation of Expedited Review of the Countervailing Duty Order C-570-048 See the Federal Register notification
China (PRC) Fresh Garlic Amended Final Results of Antidumping Duty Administrative Review; 2010-2011 A-570-831 See the Federal Register notification
China (PRC) Certain Polyester Staple Fiber Final Results of the Antidumping Duty Administrative Review; 2015-2016 A-570-905 See the Federal Register notification
China (PRC) Carton Closing Staples Determinations A-570-055 See the Federal Register notification
China (PRC) Furfuryl Alcohol Scheduling of an Expedited Five-Year Review A-570-835 See the Federal Register notification
China (PRC) 1-Hydroxyethylidene-1, 1-Diphosphonic Acid Amended Final Determination of Sales at Less Than Fair Value, and Antidumping Duty Order A-570-045 See the Federal Register notification
China (PRC) 1-Hydroxyethylidene-1, 1-Diphosphonic Acid Countervailing Duty Order C-570-046 See the Federal Register notification
China (PRC) Certain Aluminum Foil Postponement of Preliminary Determination of Countervailing Duty Investigation C-570-054 See the Federal Register notification
China (PRC) Steel Wire Garment Hangers Notice of Court Decision Not in Harmony With Final Results of Administrative Review and New Shipper Review and Notice of Amended Final Results Pursuant to Court Decision A-570-918 See the Federal Register notification
China (PRC) Certain Cold-Drawn Mechanical Tubing of Carbon and Alloy Steel Initiation of Less-Than-Fair-Value Investigations A-570-058 See the Federal Register notification
China (PRC) Certain Cold-Drawn Mechanical Tubing of Carbon and Alloy Steel Initiation of Countervailing Duty Investigations C-570-059 See the Federal Register notification
China (PRC) Helical Spring Lock Washers Determinations A-570-822 See the Federal Register notification
China (PRC) Multilayered Wood Flooring Final Results and Partial Rescission of Countervailing Duty Administrative Review; 2014 C-570-971 See the Federal Register notification
China (PRC) Certain Activated Carbon Notice of Court Decision Not in Harmony With Final Results of Administrative Review and Notice of Amended Final Results With Respect to Ningxia Huahui Activated Carbon Company, Ltd. A-570-904 See the Federal Register notification
China (PRC) 1-Hydroxyethylidene-1, 1-Diphosphonic Acid (“HEDP”) Determinations A-570-045 See the Federal Register notification
China (PRC) 1-Hydroxyethylidene-1, 1-Diphosphonic Acid (“HEDP”) Determinations C-570-046 See the Federal Register notification
China (PRC) Certain Tool Chests and Cabinets Initiation of Less-Than-Fair-Value Investigations A-570-056 See the Federal Register notification
China (PRC) Sulfanilic Acid Continuation of Antidumping Duty Orders A-533-806 See the Federal Register notification
China (PRC) Certain Tissue Paper Products Initiation of Antidumping Duty Administrative Reviews A-570-894 See the Federal Register notification
China (PRC) Glycine Initiation of Antidumping Duty Administrative Reviews A-570-836 See the Federal Register notification
China (PRC) Small Diameter Graphite Electrodes Initiation of Antidumping Duty Administrative Reviews A-570-929 See the Federal Register notification
China (PRC) Certain Tool Chests and Cabinets Initiation of Countervailing Duty Investigation C-570-057 See the Federal Register notification
China (PRC) Certain Steel Threaded Rod Preliminary Results of the Antidumping Duty Administrative Review and Rescission of Antidumping Duty Administrative Review, in Part; 2015-2016 A-570-932 See the Federal Register notification
China (PRC) Drawn Stainless Steel Sinks Preliminary Results of the Antidumping Duty Administrative Review and Preliminary Determination of No Shipments; 2015-2016 A-570-983 See the Federal Register notification
China (PRC) Certain Activated Carbon Preliminary Results of Antidumping Duty Administrative Review; 2015-2016 A-570-904 See the Federal Register notification
China (PRC) Polyethylene Terephthalate Film, Sheet, and Strip Rescission of Antidumping Duty Administrative Review; 2015-2016 A-570-924 See the Federal Register notification
China (PRC) Certain Aluminum Foil Notice of Extension of Time for Public Comment Regarding Status of the People’s Republic of China as a Nonmarket Economy Country Under the Antidumping Duty Laws A-570-053 See the Federal Register notification
China (PRC) Tow-Behind Lawn Groomers and Parts Thereof Rescission of Antidumping Duty Administrative Review; 2015-2016 A-570-939 See the Federal Register notification
China (PRC) Foundry Coke Initiation of Five-Year (“Sunset”) Reviews A-570-862 See the Federal Register notification
China (PRC) High Pressure Steel Cylinders Initiation of Five-Year (“Sunset”) Reviews A-570-977 See the Federal Register notification
China (PRC) High Pressure Steel Cylinders Initiation of Five-Year (“Sunset”) Reviews C-570-978 See the Federal Register notification
China (PRC) Furfuryl Alcohol Final Results of Expedited Fourth Sunset Review of Antidumping Duty Order A-570-835 See the Federal Register notification
China (PRC) Aluminum Extrusions Antidumping Duty Order, Finding, or Suspended Investigation; Opportunity To Request Administrative Review A-570-967 See the Federal Register notification
China (PRC) Circular Welded Carbon Quality Steel Line Pipe Antidumping Duty Order, Finding, or Suspended Investigation; Opportunity To Request Administrative Review A-570-935 See the Federal Register notification
China (PRC) Citric Acid and Citrate Salt Antidumping Duty Order, Finding, or Suspended Investigation; Opportunity To Request Administrative Review A-570-937 See the Federal Register notification
China (PRC) Iron Construction Castings Antidumping Duty Order, Finding, or Suspended Investigation; Opportunity To Request Administrative Review A-570-502 See the Federal Register notification
China (PRC) Oil Country Tubular Goods Antidumping Duty Order, Finding, or Suspended Investigation; Opportunity To Request Administrative Review A-570-943 See the Federal Register notification
China (PRC) Polyethylene Terephthalate Resin Antidumping Duty Order, Finding, or Suspended Investigation; Opportunity To Request Administrative Review A-570-024 See the Federal Register notification
China (PRC) Pure Magnesium Antidumping Duty Order, Finding, or Suspended Investigation; Opportunity To Request Administrative Review A-570-832 See the Federal Register notification
China (PRC) Stilbenic Optical Brightening Agents Antidumping Duty Order, Finding, or Suspended Investigation; Opportunity To Request Administrative Review A-570-972 See the Federal Register notification
China (PRC) Aluminum Extrusions Countervailing Duty Order, Finding, or Suspended Investigation; Opportunity To Request Administrative Review C-570-968 See the Federal Register notification
China (PRC) Citric Acid and Citrate Salt Countervailing Duty Order, Finding, or Suspended Investigation; Opportunity To Request Administrative Review C-570-938 See the Federal Register notification
China (PRC) Polyethylene Terephthalate Resin Countervailing Duty Order, Finding, or Suspended Investigation; Opportunity To Request Administrative Review C-570-025 See the Federal Register notification
China (PRC) High Pressure Steel Cylinders Institution of Five-Year Reviews A-570-977 See the Federal Register notification
China (PRC) High Pressure Steel Cylinders Institution of Five-Year Reviews C-570-978 See the Federal Register notification
China (PRC) Foundry Coke Institution of a Five-Year Review A-570-862 See the Federal Register notification
France Certain Carbon and Alloy Steel Cut-To-Length Plate Amended Final Affirmative Antidumping Determinations A-427-828 See the Federal Register notification
France Carbon and Alloy Steel Cut-to-Length Plate Determinations A-427-828 See the Federal Register notification
Germany Certain Carbon and Alloy Steel Cut-To-Length Plate Amended Final Affirmative Antidumping Determinations A-428-844 See the Federal Register notification
Germany Carbon and Alloy Steel Cut-to-Length Plate Determinations A-428-844 See the Federal Register notification
Germany Certain Cold-Drawn Mechanical Tubing of Carbon and Alloy Steel Initiation of Less-Than-Fair-Value Investigations A-428-845 See the Federal Register notification
India Certain Oil Country Tubular Goods Rescission of Countervailing Duty Administrative Review; 2015 C-533-858 See the Federal Register notification
India Frozen Warmwater Shrimp Determinations A-533-840 See the Federal Register notification
India Certain Cold-Drawn Mechanical Tubing of Carbon and Alloy Steel Initiation of Less-Than-Fair-Value Investigations A-533-873 See the Federal Register notification
India Certain Cold-Drawn Mechanical Tubing of Carbon and Alloy Steel Initiation of Countervailing Duty Investigations C-533-874 See the Federal Register notification
India Sulfanilic Acid Continuation of Antidumping Duty Orders A-570-815 See the Federal Register notification
India Sulfanilic Acid Continuation of Countervailing Duty Orders C-533-807 See the Federal Register notification
India Welded Carbon Steel Pipe and Tube Antidumping Duty Order, Finding, or Suspended Investigation; Advance Notification of Sunset Reviews A-533-502 See the Federal Register notification
India Polyethylene Terephthalate Resin Antidumping Duty Order, Finding, or Suspended Investigation; Opportunity To Request Administrative Review A-533-861 See the Federal Register notification
India Silicomanganese Antidumping Duty Order, Finding, or Suspended Investigation; Opportunity To Request Administrative Review A-533-823 See the Federal Register notification
India Welded Carbon Steel Pipe and Tube Antidumping Duty Order, Finding, or Suspended Investigation; Opportunity To Request Administrative Review A-533-502 See the Federal Register notification
India Polyethylene Terephthalate Resin Countervailing Duty Order, Finding, or Suspended Investigation; Opportunity To Request Administrative Review C-533-862 See the Federal Register notification
Indonesia Biodiesel Determinations  C-560-831 See the Federal Register notification
Indonesia Biodiesel Determinations  A-560-830 See the Federal Register notification
Indonesia Certain Uncoated Paper Initiation of Antidumping Duty Administrative Reviews A-560-828 See the Federal Register notification
Indonesia Certain Uncoated Paper Initiation of Countervailing Duty Administrative Reviews C-560-829 See the Federal Register notification
Indonesia Polyethylene Retail Carrier Bags Antidumping Duty Order, Finding, or Suspended Investigation; Opportunity To Request Administrative Review A-560-822 See the Federal Register notification
Italy Certain Carbon and Alloy Steel Cut-To-Length Plate Antidumping Duty Orders A-475-834 See the Federal Register notification
Italy Carbon and Alloy Steel Cut-to-Length Plate Determinations A-475-834 See the Federal Register notification
Italy Carbon and Certain Alloy Steel Wire Rod Determinations A-475-836 See the Federal Register notification
Italy Carbon and Certain Alloy Steel Wire Rod Determinations C-475-837 See the Federal Register notification
Italy Certain Cold-Drawn Mechanical Tubing of Carbon and Alloy Steel Initiation of Less-Than-Fair-Value Investigations A-475-838 See the Federal Register notification
Italy Stainless Steel Butt-Weld Pipe Fitting Antidumping Duty Order, Finding, or Suspended Investigation; Advance Notification of Sunset Reviews A-475-828 See the Federal Register notification
Japan Certain Carbon and Alloy Steel Cut-To-Length Plate Antidumping Duty Orders A-588-875 See the Federal Register notification
Japan Carbon and Alloy Steel Cut-to-Length Plate Determinations A-588-875 See the Federal Register notification
Japan Steel Concrete Reinforcing Bar Final Affirmative Determination of Sales at Less Than Fair Value A-588-876 See the Federal Register notification
Japan Tin Mill Products Initiation of Five-Year (“Sunset”) Reviews A-588-854 See the Federal Register notification
Japan Diffusion-Annealed Nickel-Plated Flat-Rolled Steel Products Antidumping Duty Order, Finding, or Suspended Investigation; Opportunity To Request Administrative Review A-588-869 See the Federal Register notification
Japan Gray Portland Cement and Cement Clinker Antidumping Duty Order, Finding, or Suspended Investigation; Opportunity To Request Administrative Review A-588-815 See the Federal Register notification
Japan Tin- and Chromium-Coated Steel Sheet Institution of a Five-Year Review A-588-854 See the Federal Register notification
Kazakhstan Silicon Metal Postponement of Preliminary Determinations of Countervailing Duty Investigations C-834-808 See the Federal Register notification
Kazakhstan Silicomanganese Antidumping Duty Order, Finding, or Suspended Investigation; Opportunity To Request Administrative Review A-834-807 See the Federal Register notification
Malaysia Polyethylene Retail Carrier Bags Final Results of Antidumping Duty Administrative Review; 2015-2016 A-557-813 See the Federal Register notification
Malaysia Stainless Steel Butt-Weld Pipe Fitting Antidumping Duty Order, Finding, or Suspended Investigation; Advance Notification of Sunset Reviews A-557-809 See the Federal Register notification
Mexico Carbon and Certain Alloy Steel Wire Rod Final Results of Antidumping Duty Administrative Review and Final Determination of No Shipments; 2014-2015 A-201-830 See the Federal Register notification
Mexico Large Residential Washers Initiation of Antidumping Duty Administrative Reviews A-201-842 See the Federal Register notification
Mexico Circular Welded Non-Alloy Steel Pipe Antidumping Duty Order, Finding, or Suspended Investigation; Advance Notification of Sunset Reviews A-201-805 See the Federal Register notification
Oman Polyethylene Terephthalate Resin Antidumping Duty Order, Finding, or Suspended Investigation; Opportunity To Request Administrative Review A-523-810 See the Federal Register notification
Philippines Stainless Steel Butt-Weld Pipe Fitting Antidumping Duty Order, Finding, or Suspended Investigation; Advance Notification of Sunset Reviews A-565-801 See the Federal Register notification
Portugal Certain Uncoated Paper Initiation of Antidumping Duty Administrative Reviews  A-471-807 See the Federal Register notification
Republic of Korea Certain Carbon and Alloy Steel Cut-To-Length Plate Amended Final Affirmative Antidumping Determinations A-580-887 See the Federal Register notification
Republic of Korea Certain Carbon and Alloy Steel Cut-to-Length Plate Countervailing Duty Order C-580-888 See the Federal Register notification
Republic of Korea Carbon and Alloy Steel Cut-to-Length Plate Determinations A-580-887 See the Federal Register notification
Republic of Korea Carbon and Alloy Steel Cut-to-Length Plate Determinations C-580-888 See the Federal Register notification
Republic of Korea Welded ASTM A-312 Stainless Steel Pipe Final Results of Antidumping Duty Administrative Review and Final Determination of No Shipments; 2014-2015 A-580-810 See the Federal Register notification
Republic of Korea Carbon and Certain Alloy Steel Wire Rod Determinations A-580-891 See the Federal Register notification
Republic of Korea Certain Welded Stainless Steel Pipe Determinations A-580-810 See the Federal Register notification
Republic of Korea Certain Cold-Drawn Mechanical Tubing of Carbon and Alloy Steel Initiation of Less-Than-Fair-Value Investigations A-580-892 See the Federal Register notification
Republic of Korea Ferrovanadium Antidumping Duty Order A-580-886 See the Federal Register notification
Republic of Korea Ferrovanadium Determinations A-580-886 See the Federal Register notification
Republic of Korea Large Residential Washers Initiation of Antidumping Duty Administrative Reviews A-580-868 See the Federal Register notification
Republic of Korea Cut-To-Length Carbon-Quality Steel Plate Initiation of Countervailing Duty Administrative Reviews C-580-837 See the Federal Register notification
Republic of Korea Circular Welded Non-Alloy Steel Pipe Antidumping Duty Order, Finding, or Suspended Investigation; Advance Notification of Sunset Reviews A-580-809 See the Federal Register notification
Republic of Korea Polyester Staple Fiber Antidumping Duty Order, Finding, or Suspended Investigation; Opportunity To Request Administrative Review A-580-839 See the Federal Register notification
Russia Carbon and Certain Alloy Steel Wire Rod Determinations A-821-824 See the Federal Register notification
South Africa Carbon and Certain Alloy Steel Wire Rod Determinations A-791-823 See the Federal Register notification
South Africa Stainless Steel Plate in Coils Antidumping Duty Order, Finding, or Suspended Investigation; Opportunity To Request Administrative Review A-791-805 See the Federal Register notification
South Africa Stainless Steel Plate in Coils Countervailing Duty Order, Finding, or Suspended Investigation; Opportunity To Request Administrative Review C-791-806 See the Federal Register notification
Spain Carbon and Certain Alloy Steel Wire Rod Determinations A-469-816 See the Federal Register notification
Spain Stainless Steel Bar Initiation of Antidumping Duty Administrative Reviews A-469-805 See the Federal Register notification
Switzerland Certain Cold-Drawn Mechanical Tubing of Carbon and Alloy Steel Initiation of Less-Than-Fair-Value Investigations A-441-801 See the Federal Register notification
Taiwan Certain Helical Spring Lock Washers Continuation of Antidumping Duty Orders A-583-820 See the Federal Register notification
Taiwan Certain Carbon and Alloy Steel Cut-To-Length Plate Amended Final Affirmative Antidumping Determinations A-583-858 See the Federal Register notification
Taiwan Carbon and Alloy Steel Cut-to-Length Plate Determinations A-583-858 See the Federal Register notification
Taiwan Certain Circular Welded Carbon Steel Pipes and Tubes Preliminary Results of Antidumping Duty Administrative Review and Preliminary Determination of No Shipments; 2015-2016 A-583-008 See the Federal Register notification
Taiwan Certain Welded Stainless Steel Pipe Determinations A-583-815 See the Federal Register notification
Taiwan Helical Spring Lock Washers Determinations A-583-820 See the Federal Register notification
Taiwan Light-Walled Welded Rectangular Carbon Steel Tubing Final Results of the Expedited Fourth Sunset Review of the Antidumping Duty Order A-583-803 See the Federal Register notification
Taiwan Light-Walled Rectangular (LWR) Pipe and Tube Scheduling of an Expedited Five-Year Review A-583-803 See the Federal Register notification
Taiwan Circular Welded Non-Alloy Steel Pipe Antidumping Duty Order, Finding, or Suspended Investigation; Advance Notification of Sunset Reviews A-583-814 See the Federal Register notification
Taiwan Certain Circular Welded Carbon Steel Pipe and Tubes Antidumping Duty Order, Finding, or Suspended Investigation; Advance Notification of Sunset Reviews A-583-008 See the Federal Register notification
Taiwan Certain Circular Welded Carbon Steel Pipes and Tubes Antidumping Duty Order, Finding, or Suspended Investigation; Opportunity To Request Administrative Review A-583-008 See the Federal Register notification
Taiwan Polyester Staple Fiber Antidumping Duty Order, Finding, or Suspended Investigation; Opportunity To Request Administrative Review A-583-833 See the Federal Register notification
Taiwan Polyethylene Retail Carrier Bags Antidumping Duty Order, Finding, or Suspended Investigation; Opportunity To Request Administrative Review A-583-843 See the Federal Register notification
Taiwan Stainless Steel Plate in Coils Antidumping Duty Order, Finding, or Suspended Investigation; Opportunity To Request Administrative Review A-583-830 See the Federal Register notification
Taiwan Stilbenic Optical Brightening Agents Antidumping Duty Order, Finding, or Suspended Investigation; Opportunity To Request Administrative Review A-583-848 See the Federal Register notification
Thailand Frozen Warmwater Shrimp Determinations A-549-822 See the Federal Register notification
Thailand Circular Welded Carbon Steel Pipes and Tubes Initiation of Antidumping Duty Administrative Reviews  A-549-502 See the Federal Register notification
Thailand Certain Circular Welded Carbon Steel Pipe and Tubes Antidumping Duty Order, Finding, or Suspended Investigation; Advance Notification of Sunset Reviews A-549-502 See the Federal Register notification
Turkey Circular Welded Carbon Steel Pipes and Tubes Rescission of Countervailing Duty Administrative Review; 2016 C-489-502 See the Federal Register notification
Turkey Steel Concrete Reinforcing Bar Final Determination of Sales at Less Than Fair Value A-489-829 See the Federal Register notification
Turkey Steel Concrete Reinforcing Bar Final Affirmative Countervailing Duty Determination C-489-830 See the Federal Register notification
Turkey Carbon and Certain Alloy Steel Wire Rod Determinations A-489-831 See the Federal Register notification
Turkey Carbon and Certain Alloy Steel Wire Rod Determinations C-489-832 See the Federal Register notification
Turkey Welded Line Pipe Rescission, in Part, of Countervailing Duty Administrative Review; 2015 C-489-823 See the Federal Register notification
Turkey Circular Welded Carbon Steel Pipes and Tubes Initiation of Countervailing Duty Administrative Reviews C-489-502 See the Federal Register notification
Turkey Certain Circular Welded Carbon Steel Pipe and Tubes Antidumping Duty Order, Finding, or Suspended Investigation; Advance Notification of Sunset Reviews A-489-501 See the Federal Register notification
Turkey Certain Circular Welded Carbon Steel Pipe and Tubes Countervailing Duty Order, Finding, or Suspended Investigation; Advance Notification of Sunset Reviews C-489-502 See the Federal Register notification
Turkey Circular Welded Carbon Steel Pipes and Tubes Antidumping Duty Order, Finding, or Suspended Investigation; Opportunity To Request Administrative Review A-489-501 See the Federal Register notification
Turkey Light-Walled Rectangular Pipe and Tube Antidumping Duty Order, Finding, or Suspended Investigation; Opportunity To Request Administrative Review A-489-815 See the Federal Register notification
UAE Certain Steel Nails Preliminary Results of Antidumping Duty Administrative Review; 2015-2016 A-520-804 See the Federal Register notification
UAE Carbon and Certain Alloy Steel Wire Rod Determinations A-520-808 See the Federal Register notification
UAE Polyethylene Terephthalate Film, Sheet and Strip Partial Rescission of Antidumping Duty Administrative Review; 2015-2016 A-520-803 See the Federal Register notification
UAE Steel Nails Antidumping Duty Order, Finding, or Suspended Investigation; Opportunity To Request Administrative Review A-520-804 See the Federal Register notification
Ukraine Carbon and Certain Alloy Steel Wire Rod Determinations A-823-816 See the Federal Register notification
Ukraine Silicomanganese Preliminary Results of Antidumping Duty Administrative Review; 2015-2016 A-823-805 See the Federal Register notification
United Kingdom Carbon and Certain Alloy Steel Wire Rod Determinations A-412-826 See the Federal Register notification
Venezuela Silicomanganese Antidumping Duty Order, Finding, or Suspended Investigation; Opportunity To Request Administrative Review A-307-820 See the Federal Register notification
Vietnam Utility Scale Wind Towers Notice of Amended Initiation of Antidumping Duty Administrative Review; 2016-2017 A-552-814 See the Federal Register notification
Vietnam Certain Oil Country Tubular Goods Rescission of Antidumping Duty Administrative Review; 2015-2016 A-552-817 See the Federal Register notification
Vietnam Steel Wire Garment Hangers Rescission of Countervailing Duty Administrative Review; 2016 C-552-813 See the Federal Register notification
Vietnam Frozen Warmwater Shrimp Determinations A-552-802 See the Federal Register notification
Vietnam Certain Tool Chests and Cabinets Initiation of Less-Than-Fair-Value Investigations A-552-821 See the Federal Register notification
Vietnam Steel Wire Garment Hangers Rescission of Antidumping Duty Administrative Review; 2016-2017 A-552-812 See the Federal Register notification
Vietnam Polyethylene Retail Carrier Bags Antidumping Duty Order, Finding, or Suspended Investigation; Opportunity To Request Administrative Review A-552-806 See the Federal Register notification
Vietnam Polyethylene Retail Carrier Bags Countervailing Duty Order, Finding, or Suspended Investigation; Opportunity To Request Administrative Review C-552-805 See the Federal Register notification

Tax Treaty News: April 2017

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Ireland and Kazakhstan On 27 April 2017, the Double Taxation Agreement (DTA) between Ireland and Kazakhstan was signed for the avoidance of double taxation and the prevention of fiscal evasion with respect to taxes on income.
Pakistan and Bulgaria On 26 April 2017, the Double Taxation Agreement (DTA) between Pakistan and Bulgaria was signed for the avoidance of double taxation and the prevention of fiscal evasion with respect to taxes on income.
Bahrain and Thailand On 25 April 2017, Bahrain and Thailand signed an amending protocol of Double Taxation Agreement (DTA) for the avoidance of double taxation and the prevention of fiscal evasion with respect to taxes on income in Manama.
Latvia and Singapore On 20 April 2017, Latvia and Singapore signed an amending protocol of Double Taxation Agreement (DTA) for the avoidance of double taxation and the prevention of fiscal evasion with respect to taxes on income, in Washington DC.
Andorra and United Arab Emirates On 20 April 2017, the general council of Andorra approved the Double Taxation Agreement (DTA) with United Arab Emirates for the avoidance of double taxation and the prevention of fiscal evasion with respect to taxes on income.
India and Portugal According to a press release of 19 April 2017, the Union Cabinet of India has given its approval for signing of a Protocol amending the Convention with Portugal for avoidance of double taxation. The Protocol will also ensure prevention of fiscal evasion with respect to taxes on income.
Netherlands and Uzbekistan On 19 April 2017, the President of Uzbekistan signed a Decree ratifying the amending protocol of Double Taxation Agreement (DTA) with Netherlands.
Belarus and Hong Kong On 19 April 2017, the Belarusian Lower Chamber of Parliament approved the Double Taxation Agreement (DTA) with Hong Kong.
Bangladesh and Bhutan On 18 April 2017, the Double Taxation Agreement (DTA) between Bangladesh and Bhutan was signed in Thimphu.
Bahrain and Philippines On 13 April 2017, the amending protocol of Double Taxation Agreement (DTA) between Bahrain and Philippines was signed.
Malta and Ukraine On 13 April 2017, the parliament of Ukraine passed a law ratifying the Double Taxation Agreement (DTA) with Malta for the avoidance of double taxation and the prevention of fiscal evasion with respect to taxes on income.
Czech Republic and Ghana On 11 April 2017, the Double Taxation Agreement (DTA) between Czech Republic and Ghana was signed in Accra.
Bahrain and Philippines On 10 April 2017, the Cabinet of Bahrain authorized the Minister of Finance (MoF) to sign an amending protocol of Double Taxation Agreement (DTA) with Philippines.
Estonia and Kyrgyzstan On 10 April 2017, the Double Taxation Agreement (DTA) between Estonia and Kyrgyzstan was signed in Estonia.
Romania and Uzbekistan On 10 April 2017, the Senate of Romania approved the amending protocol of Double Taxation Agreement (DTA) with Uzbekistan.
Romania and China On 10 April 2017, the Senate of Romania approved the Double Taxation Agreement (DTA) with China for the avoidance of double taxation and the prevention of fiscal evasion with respect to taxes on income.
Azerbaijan and Israel On 7 April 2017, the parliament of Azerbaijan approved the Double Taxation Agreement (DTA) with Israel.
Malawi and Zambia On 6 April 2017, the Double Taxation Agreement (DTA) between Malawi and Zambia was signed in Lusaka.
Cameroon and South Africa On 6 April 2017, the Senate of Cameroon approved the Double Taxation Agreement (DTA) with South Africa for the avoidance of double taxation and the prevention of fiscal evasion with respect to taxes on income.
Rwanda and Morocco On 5 April 2017, the Council of Ministers of Rwanda approved the Double Taxation Agreement (DTA) with Morocco for the avoidance of double taxation and the prevention of fiscal evasion with respect to taxes on income.
Ukraine and Luxembourg On 3 April 2017, the President of Ukraine signed a law ratifying the amending protocol of Double Taxation Agreement (DTA) with Luxembourg for the avoidance of double taxation and the prevention of fiscal evasion with respect to taxes on income.
Azerbaijan and Kazakhstan On 3 April 2017, Azerbaijan and Kazakhstan signed an amending protocol of Double Taxation Agreement (DTA) for the avoidance of double taxation and the prevention of fiscal evasion with respect to taxes on income, in Baku.
Kenya and Korea (Rep) On 3 April 2017, the Double Taxation Agreement (DTA) between Kenya and Korea (Rep.) was entered into force for the avoidance of double taxation and the prevention of fiscal evasion with respect to taxes on income. This treaty will apply from 1 January 2018.
Ghana and Singapore On 31 March 2017, the Double Taxation Agreement (DTA) between Singapore and Ghana was signed in Ghana for the avoidance of double taxation and the prevention of fiscal evasion with respect to taxes on income.
Qatar and Spain On 31 March 2017, the Council of Ministers of Spain approved the Double Taxation Agreement (DTA) with Qatar for the avoidance of double taxation and the prevention of fiscal evasion with respect to taxes on income.
Armenia and Germany On 31 March 2017, the German Federal Council of ministers approved the Double Taxation Agreement (DTA) with Armenia. Once in force and effective, the treaty will replace the existing DTA of 1981.
Germany and Macedonia On 31 March 2017, the Federal Council of Germany approved the amending protocol of Double Taxation Agreement (DTA) with Macedonia.
France and Portugal On 30 March 2017, the Council of Ministers of France approved the amending protocol of Double Taxation Agreement (DTA) with Portugal.
Japan and Latvia On 30 March 2017, Latvia ratified the Double Taxation Agreement (DTA) with Japan for the avoidance of double taxation and the prevention of fiscal evasion with respect to taxes on income.
Romania and China On 28 February 2017, the Chamber of Deputies of Romania approved the Double Taxation Agreement (DTA) with China. Once in force and effective, the new treaty will replace the existing DTA of 1991.
Romania and Uzbekistan On 28 February 2017, Romania has approved the amending protocol to Double Taxation Agreement (DTA) with Uzbekistan for the avoidance of double taxation and the prevention of fiscal evasion with respect to taxes on income.
Bangladesh and Bhutan On 27 February 2017, the cabinet of Bangladesh authorized the signing of a Double Taxation Agreement (DTA) with Bhutan for the avoidance of double taxation and the prevention of fiscal evasion with respect to taxes on income.
Bangladesh and Qatar On 27 February 2017, the cabinet of Bangladesh authorized the signing of a Double Taxation Agreement (DTA) with Qatar for the avoidance of double taxation and the prevention of fiscal evasion with respect to taxes on income.
United States and Vietnam In accordance with resolution 29/NQ-CP of 24 February 2017, Vietnam ratified the Double Taxation Agreement (DTA) with United States for the avoidance of double taxation and the prevention of fiscal evasion with respect to taxes on income.
India and Vietnam On 21 February 2017, the amending protocol of Double Taxation Agreement (DTA) between India and Vietnam was entered into force. This protocol will apply from 1 April 2018 in India and from 1 January 2018 in Vietnam.
Jersey and Cyprus On 17 February 2017, the Double Taxation Agreement (DTA) between Jersey and Cyprus was entered into force for the avoidance of double taxation and the prevention of fiscal evasion with respect to taxes on income. This treaty will apply from 1 January 2018.
Panama and Vietnam On 14 February 2017, the Double Taxation Agreement (DTA) between Vietnam and Panama was entered into force. This treaty will apply from 1 January 2018.
New Zealand and British Virgin Islands On 23 December 2016, the Double Taxation Agreement (DTA) between New Zealand and British Virgin Islands was entered into force for the avoidance of double taxation and the prevention of fiscal evasion with respect to taxes on income. This agreement applied from 1 April 2017 for New Zealand and 1 January 2017 for the British Virgin Islands.
Uzbekistan and Pakistan On 25 October 2016, the amending protocol between Uzbekistan and Pakistan was entered into force that was signed on 17 November 2015. This protocol is applicable as of 1 January 2017.

Transfer Pricing Brief: April 2017

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China: Adjustments-MAP: Bulletin 6 governs MAP in relation to bilateral/multilateral APAs and special tax adjustments in one jurisdiction which would result in corresponding adjustment in another jurisdiction. According to Bulletin 6, the SAT may initiate a MAP upon the request of an enterprise or the competent authority of the other contracting state. Taxpayers with ongoing special tax investigations or those who have not paid taxes assessed in an investigation may be denied access to MAP.
Special Areas-Intangible property- Hard to value intangibles: China contains the five functions in SAT Bulletin 6 including development, enhancement, maintenance, protection and exploitation (DEMPE functions) under OECD guidelines that are relevant in determining the allocation of profits from use of intangible property. In addition, Bulletin 6 added promotion as a sixth function to signify the importance China places on value created through marketing activities undertaken by Chinese companies.
General for Intra-group services: SAT Bulletin 6 encompasses the provision of empowerment of tax authorities to refuse a deduction for service fees paid to a related party that does not have particular effect. The Bulletin maintains internationally accepted and OECD sanctioned benefit test.
Location specific advantages for business restructurings: Bulletin 6 incorporates comparability analysis in requiring LSA adjustments. Multinational entity may face an increasing number of cases where the tax authorities make transfer pricing adjustments based on LSAs.
Priority of Methods: SAT Bulletin 6 highlights the TNMM method which is generally not appropriate in transactions where the tested party has significant intangible assets. Bulletin 6 provides that a high and new technology enterprise should apply the profit split method so that a higher portion of profit will be allocated to the high and new technology enterprise.
Other methods: Bulletin 6 introduces additional asset valuation and catchall method that must be applied consistently with the arm’s length principle.
See the story in Regfollower
UK: General rule for CbC reporting requirement: The Statutory Instrument No. 497 of 30 March 2017, amends SI 2016 No. 237, which gives effect in the G20/OECD’s minimum standard for country-by-country (CbC) information needed to be provided to the tax authorities. Additionally, the regulations ensure compliance with the amended EU Council Directive on Administrative Cooperation 2011/15/EU (DAC4). Furthermore, country-by-country reporting obligation now applies to MNE groups whose ultimate parent entities are governed under UK law, including limited liability partnerships.
Timing for CbC reporting requirement: Statutory Instrument 2017 (No. 497), published on 30 March 2017 governs new annual notification requirements for UK entities, with the first notifications due on 1 September 2017 and then by the end of the CbC reporting period thereafter.
See the story in Regfollower
Poland: General rule for CbC reporting requirement: On 20 March 2017, the new legislation regarding the exchange of tax information with other countries entered into force.  The Law provides information on obligations of financial institutions (FIs) and the automatic exchange of country-by-country (CbC) reports. Entities belonging to groups whose have registered office or permanent establishment (PE) in Poland shall provide the group information for the reporting year.
Information exchange-Multilateral: On 20 March 2017, the new legislation regarding the exchange of tax information with other countries entered into force.  The new legislation provides rules concerning the exchange of information including revenue, realized gain (loss) before tax, income tax paid and payable, capital, ROE, number of employees and tangible assets other than cash and cash equivalents.
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Germany: General rule for CbC reporting requirement: The German Federal Ministry of Finance recently published a draft discussion paper on transfer pricing documentation. The proposed draft TP documentation decree correspond mainly the OECD Guidance defining the relevant information to be included in the Master File and the Local File.
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New Zealand: BEPS related compliance: On 3 March 2017, the Revenue and Finance Minister released three BEPS related consultation papers which address the issue of Base Erosion and Profit Shifting (BEPS). The consultation papers proposed new measures to strengthen New Zealand’s rules for taxing large multinationals. Submissions on the consultation document on implementing the international convention are open until 7 April. Submissions on the other two are open until 18 April. Ministers will consider final proposals arising from the documents later in the year.
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Ukraine: Documentation-Requirement: Effective from 1 January 2017, in addition to the previous requirements transfer pricing documentation is expanded including copies of the agreements specifying terms and conditions of the controlled transactions; information about the payments made in the transaction; information about the taxpayers involved in the business; information about the cost allocation algorithm used in calculating the profit level indicator; and description and calculation of comparability adjustments of terms and financial results of the controlled and uncontrolled transaction.
Documentation-Thresholds: Starting from 1 January 2017, criteria for tracing controlled transactions is increased with annual income of at least USD 5.4m (1.8 million in 2016) and with transactions with a single counterparty of more than USD 357000 thousand (179,000 in 2016).
Documentation-Deadline: The deadline for submitting the report of controlled transactions has been changed from previous date of 1 May to 1 October of the year following the reporting year.
Comparability-Range: Effective form 1 January 2017, taxpayers will be able to adjust their taxable profit for Transfer Pricing purposes to maximum or minimum values of the range of prices instead of the median.
Comparability analysis: Effective from 1 January 2017, it is possible to determine a profitability margin and perform a benchmarking study if no direct comparable data is available and in such cases, the benchmarking study can be done based on financial information  of comparable legal entities.
Penalty for documentation failure: Starting from January 2017, penalties are based on the living wage for persons capable of work as of January 1 of the reporting year (previously penalties were based on the minimum wage). In case of non-submission of report on controlled transaction 300 living wages is imposed. For late submission of report on controlled transactions, 1 living wage for each calendar day of the delay but not more than 300 living wages. Failure to declare a controlled transaction in report on controlled transactions, 1 % of undeclared amount but not more than 300 living wages. For late declaration of controlled transactions, 1 living wage for each calendar day of the delay but not more than 300 living wages. Failure to submit TP documentation, 3% of the amount that document was not submitted but not more than 200 living wages. For delayed submission of TP documentation, 2 living wage for each calendar day of the delay but not more than 200 living wages. Failure to submit the report on controlled transactions or transfer pricing documentation within 30 calendar days following the last day of the payment of the penalty, 5 living wages for each calendar day of non-submission after expiration of 30 calendar days.
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Cyprus: Information exchange-Multilateral: On 5 April 2017, the Council of Ministers approved the signing of the OECD Multilateral Instrument (MLI) Convention of 2016. The signing formality is scheduled to take place on 7 June 2017.
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Czech Republic: General rule for CbC reporting requirement: According to proposed amending legislation to become effective on 5 June 2017, the CbC report will be mandatory for multinational groups with an annual consolidated turnover exceeding €750 million. Czech companies will be obliged to prepare a CbC report on behalf of the entire multinational group if they are the ultimate parent company of the group or if they have been regulated for the purposes of CbC reporting as representing companies. If the Czech company prepares the CbC report itself, all the member companies of the group will need to be informed of the fact and it will be necessary to further communicate with them so that all the details that are necessary for preparing the CbC report may be obtained.
Timing for CbC reporting requirement: The first reporting periods in which CbC reports should be prepared are periods beginning on or after 1 January 2016. Thus, The first due date for CbC report filling is 31 December 2017. For the reporting period ending prior to 30 September 2017, the due date for first notification shall be 30 September 2017. For reporting periods ending after 30 September 2017, the due date for the notification shall be the end of the first reporting period.
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Costa Rica: BEPS related compliance:
Master file: Costa Rica’s tax authority (Dirección General de Tributación—DGT) issued Resolution DGT-R-16-2017 on 21 April 2017. According to Resolution, taxpayers having transactions with related parties are required to keep supporting document relating to corporate and company local information. The corporate information required by the DGT is the equivalent to the “Master file” that summarizes qualitative and quantitative data from the group at the international level, as proposed by the OECD in the base erosion and profit shifting (BEPS) project.
Local file: According to Resolution DGT-R-16-2017 issued on 21 April 2017, taxpayers having transactions with related parties are required to retain supporting documentation of company local information. The company local information which is equivalent to the Local File as proposed by OECD BEPS Action 13 requires the taxpayer to provide the organization structure, chain value, financial information etc.
Penalty for non-compliance: A penalty of USD 90,000 applies for failure to comply BEPS related compliance as per the requirements of Resolution DGT-R-16-2017 issued on 21 April 2017.
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Australia: Documentation requirement-Master file: According to ATO’s guideline, for preparing and lodging the Master file XML schema is required to be developed in in house, licensed or outsourced. While the master file XML schema contains questions in relation to taxpayer’s lodgment of the Country-by-Country (CbC) report, the CbC report itself must be lodged separately in accordance with the OECD XML. CbC statements including master file and local file must be lodged via one of the channel provided by Australian Taxation Office (ATO).
Documentation requirement-Local file: According to ATO’s guideline, for preparing and lodging the Local file XML schema is required to be developed in in house, licensed or outsourced. CbC statements including master file and local file must be lodged via one of the channel provided by Australian Taxation Office (ATO).
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Mexico: Documentation requirement-Master file: On 3 April 2017, the Mexican Tax Ombudsman published the final regulations on transfer pricing providing guidance on the master file. The final regulations allow a foreign related party to prepare the master files and Mexican taxpayers to file the master file in English or Spanish as long as it is consistent with OECD BEPS Action 13. If the Mexican taxpayer prepares the master file locally, the information provided must align with the new definitions and specific requirements included in the final regulations. The final regulations are not effective until published by the SAT in the Official Gazette.
Documentation requirement-Local file: On 3 April 2017, the Mexican Tax Ombudsman published the final regulations on transfer pricing providing guidance on local file. The local file must be filed in Spanish, except for the business description of comparable companies and agreements, which may be provided in English or Spanish. Taxpayers with an Advance Pricing Agreement (APA) or subject to the maquiladora rules will have the option to not file the local file.
General rule for CbC reporting requirement: On 3 April 2017, the Mexican Tax Ombudsman published the final regulations on transfer pricing providing guidance on CbC report. The final regulations include some clarifications and definitions for the CbC report. In addition, the final regulations allow Mexican taxpayers to file just one transfer pricing information return jointly with the entities of the multinational group.
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Netherlands:  General rule for CbC reporting requirement: On April 18, 2017, the Dutch lower house of Parliament adopted the Bill No.34651 to implement country-by-country (CbC) reporting. The bill allowed a group entity to serve as the reporting entity and a designated Dutch group entity to file an incomplete CbC report with all the information at its disposal.
Penalty for non-compliance in CbC reporting requirement: The Dutch Lower House on 18 April 2017 passed proposed Amendment No.9 which increased the penalty for noncompliance to €820,000.
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World Tax Brief: April 2017

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UK Corporate income tax rate: The corporate income tax rate in the UK has been reduced to 19% from the current 20% rate starting from 1st April 2017, in order to support investment, growth and job creation. Further, the main rate of corporation tax will be cut again to 17% by 2020, by far the lowest in the G20 and benefiting over 1 million businesses.
Incentives: According to the Chancellor’s announcement in the Autumn Statement that the government introduced the new corporation tax relief for museums and galleries. The relief will be reduced to 20% for non-touring exhibitions and 25% for tour exhibitions. The relief will be capped at £ 500,000 of the qualifying expenses per exhibition.
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US Corporate income tax rate: President Donald Trump has proposed a significant reduction of corporation tax rates to 15% from the current 35% rate. Under the Trump tax scheme, the United States would be bound by the fourth-lowest tax rate of developed nations between Germany and Poland. He also proposes a 10% tax on more than $ 2.6 trillion in the revenue that US companies have stored offshore. This would allow companies to bring money from overseas to the US with a slightly lower, one-off tax.
Alternative minimum tax:  The President also proposes the abolition of the so-called alternative minimum tax. The decade-long tax, which has been enacted to ensure that the rich pay their fair share, costs Trump 31 million dollars in 2005.
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Turkey Incentives: Turkey has introduced a new law on the reshuffle of certain public claims and the amendment of certain laws and cabinet regulations. The law allows legitimate taxpayers to benefit from tax relief if they fulfil certain conditions. The new tax relief is intended to promote the compliance level of taxpayers and allow them to benefit from a 5% tax deduction from their annual tax.
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China Corporate tax rate: The government of China plans new tax cuts to reduce the burden on businesses, support innovation and stabilise growth. On 19 April 2017, tax cuts were approved at a State Council executive meeting, after the government announced measures to decrease business costs in the first quarter.
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Brazil Withholding tax: Recently, the Brazilian tax Authorities published a withholding tax guideline ( Solução De Consulta No. 153/2017 of 2 March 2017) in order to confirm that the triggering event for the specified transaction tax the import of services should be considered when the income will be economic or legal Be available to the foreign creditor.
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Dominican Republic Incentives:  The Directorate General of Internal Taxation has recently introduced the expansion of fiscal support for the agricultural sector, which frees them from the payment of advances on income tax, the payment of the tax on assets and the inclusion of income tax on payments by the state.
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Germany Refund: Recently, the German tax administration has published an updated guidance on the tax refund procedure for non-residents to claim a refund of withholding tax on portfolio dividends. According to the new procedure, as from 1 January 2017, the income from dividends subject to a residual tax rate of 15% under an agreement.
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Hong Kong Filing return: The Inland Revenue Department of Hong Kong has recently published a list of major changes in profit tax return form [BIR51] for the year of 2016/17.
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Australia Sanctions for tax evasion: The Australian Government has introduced a new Diverted Profits Tax (DPT) Bill on 9 February 2017 into the House of Representatives. If passed, the Bill will allow the Commissioner of Taxation to tax the diverted profits of certain entities at a rate of 40%. The DPT will apply to multinationals with annual global income of AUD 1 billion or more. The DPT will apply to income years commencing on or after 1 July 2017 whether or not a relevant transaction was entered into before that date.
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Mexico Incentives: Government introduced general rules on R&D tax credit within the official gazette on 28 February 2017, this rule governs Mexico’s R&D (research and development) tax credit. Accordingly, taxpayers may claim a credit against the income tax liability equal to 30% of the investments and expenses for technological R&D in Mexico and is attributable to the income tax due for the respective fiscal year (FY). Taxpayers calculate the credit based on the incremental expenses and investments made in the current year as compared to the previous three tax years. Taxpayers have to submit their applications between 1 April and 31 May for the fiscal year 2017.
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India Computation of taxable income: The Supreme Court of India in the case of: McDowell & Company Ltd. v. CIT (Civil Appeal No. 3893 of 2006), held that the waiver of interest by financial institutions is computable from the hands of the Amalgamating Company regarding the benefit of section 72A of the Income Tax Act.
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Kenya Corporate tax rate: Kenya’s Cabinet Secretary for Finance has presented the budget for 2017 and proposed to implement the modifications for the corporate tax rate to promote the development of real estate. Accordingly,  the corporation tax rate has been reduced to 20% against corporation tax rates of 30%.
Withholding taxes: Under the budget proposal, dividends paid to non-residents by enterprises operating in Special Economic Zones will be exempt from withholding tax in order to ensure that foreign investors get a good return on their investment. Withholding tax on interest payable to non-residents by special economic zone enterprises will be reduced to 5%.
Incentives: The budget has proposed a 150% deduction incentive to the fishing sector and a 100% investment deduction for the special economic zone on buildings and machinery.
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Thailand Liability to Tax: The Revenue Department of Thailand plans to introduce a new tax on e-commerce in April 2017 to control cross-border e-commerce transactions. Currently, a foreign operator which carries on e-commerce business but does not enter Thailand or does not have any employee, agent or representative and/or server located in Thailand, were not regarded as carrying on business in Thailand and therefore are not subject to income tax in Thailand.
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