South Africa: SARS publishes draft IN18 on rebate and deduction of foreign taxes on income
On 12 September 2019, the South African Revenue Service (SARS) published draft Interpretation Note 18 (Issue 4) (IN18) regarding the rebate and deduction of foreign taxes on income for public comment. This interpretation note describes the scope,
See MoreCosta Rica publishes a resolution on the list of non-cooperative jurisdictions for tax purposes
On 25 September 2019, the Costa Rican Ministry of Finance published a resolution No. DGT-R-55-2019 on the list of non-cooperative jurisdictions for tax purposes. The list includes Bosnia and Herzegovina, Cuba, Eritrea, French Polynesia, Guadeloupe,
See MoreRussia reduces the Interest rate from September 2019
On 6 September 2019, the Russian Central Bank announced the decision to reduce the key rate from 7.25% to 7.00% with effect from 9 September 2019. For tax purposes, the key rate is important in relation to the safe harbor rates for interest
See MorePakistan: FBR approves the Finance Act 2019 with certain changes
On 30 July 2019, the Federal Board of Revenue (FBR) has issued a Circular No. 9 of 2019. The Circular contains important changes to the Income Taxation Act 2001 through the Finance Act 2019, which was published in the Official Journal on 30 June
See MoreRussia reduces the interest rate from July 2019
On 26 July 2019, the Russian Central Bank announced the decision to reduce the key rate from 7.50% to 7.25% with effect from 29 July 2019. For tax purposes, the key rate is important in relation to the safe harbor rates for interest income
See MoreMalta updates NID Guidelines
On 11 July 2019, the Maltese Commissioner for Revenue has issued updated guidelines regarding the Notional Interest Deduction (NID) rules. The updated guidelines explains a number of factors including the determination of the reference rate, the
See MoreFrance publishes interest rate for shareholder loan for FY ends between June and September 2019
Recently, France has published interest rates for entities whose financial year ended between 30 June 2019 and 29 September 2019 , which are used to determine the deductibility of interest payments to shareholders. The portion of interest payments
See MoreChina updates expense deduction limit for insurance sector
China's Ministry of Finance (MoF) has published Announcement No. 72 of 2019 regarding pre-tax deduction policy for insurance enterprise handling fees and commission expenses. The announcement provides that insurance companies may deduct up to
See MoreBrazil publishes general rules regarding shareholder interest on net equity
On 6 May 2019, Brazil has published general rules 7018 of 21 March 2019 in the official gazette clarifying calculation and deduction of interest on net equity. The calculation will take into account for the following equity
See MoreFrance publishes interest rate for shareholder loan for FY ends between March and June 2019
On 17 April 2019, France published interest rates for entities whose financial year ended between 31 March 2019 and 29 June 2019, which are used to determine the deductibility of interest payments to shareholders. The portion of interest payments
See MoreUganda: Minister of Finance presents tax reform bills to Parliament
On 28 March 2019, Mr. Matia Kasaija, the Minister of Finance, Planning and Economic Development (Minister of Finance) of Uganda presents a number of tax reforms amendment bills to the Ugandan parliament and are currently under consideration. The
See MoreChina: New rules and requirements for tax compliance
Recently promulgated Chinese tax regulations include following changes affecting corporate income tax: Increase to the unit value of fixed assets eligible for the “one-off deduction method” to RMB 5 million;Increase to the deduction limit
See MoreUK: Draft guidance on taxation of insurance companies
On 13 December 2018 HMRC issued for consultation draft guidance on the corporation tax treatment of insurance companies writing life insurance and other long term insurance business. The Life Assurance Manual is primarily written for HMRC staff
See MoreBulgaria: Consultation on draft Law for implementing EU ATAD
The Finance Ministry is consulting on draft legislation for the execution of certain measures of the EU Anti-Tax Avoidance Directive (ATAD). A new interest limitation rule was proposed in this draft Law. This new rule would restrict the amount of
See MoreHungary presents new tax package for 2019
The government of Hungary presented a new tax package on 19 June 2018 for corporate and business tax. The changes of taxes are as follows: The deduction allowance for investment in start-ups will be capped at HUF 20 million; A deduction for
See MoreLuxembourg: Government submits EU Anti-Tax Avoidance Directive (ATAD) to Parliament
On 20 June 2018, the draft law (Draft Law) implementing the European Union (EU) Anti-Tax Avoidance Directive (ATAD) was introduced in the Luxembourg Parliament. Accordingly, as from 2019, a new provision will be introduced that limits interest
See MoreSweden: Parliament approves draft bill regarding corporate income tax changes
On 14 June 2018, the Swedish Parliament approved the bill introducing new tax rules for the business sector. The bill includes following measures: A reduction in the corporate tax rate from 22% to 21.4% in 2019 and 2020, and to 20.6% from 2021;
See MoreChile: Tax authority publishes a Circular regarding transitional relief
The tax authority (SII) has released Circular No. 31 of 23 May 2018. It assures the transition relief provided regarding dividends paid by taxpayers under the partially integrated regime (PIS). The tax authority has also published Ordinance 470 and
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