US: IRS issues additional guidance for computing the “transition tax” on foreign earnings
On 19 January 2018, the Treasury Department and the Internal Revenue Service issued additional guidance (Notice 2018-13) for computing the “transition tax” on the untaxed foreign earnings of foreign subsidiaries of U.S. companies under the Tax
See MoreUS: IRS issues guidance for computing the “transition tax” on foreign earnings
On 29 December 2017, the Treasury Department and the Internal Revenue Service issued Notice 2018-07, which provides guidance for computing the “transition tax” under recent tax legislation enacted on Dec. 22, 2017. In general, newly-issued
See MoreUS Tax Cuts and Jobs Act: Global Intangible Low-Taxed Income
The US Tax Cuts and Jobs Act has introduced various new provisions to counter base erosion and profit shifting by US corporations. These include a base erosion minimum tax, provisions to counter income shifting by intangible property transfers and
See MoreUS Tax Cuts and Jobs Act: Income Shifting by Intangible Property Transfers
A U.S. person transferring intangible property to a foreign corporation in a transaction that would otherwise qualify for non-recognition treatment is generally treated as having sold the intangible property in exchange for payments contingent on
See MoreUS Tax Cuts and Jobs Act: Hybrid Transactions and Hybrid Entities
A group could set up an entity that is treated as fiscally transparent for U.S. federal tax purposes but is treated as an entity in the country in which it is resident or subject to tax. Similarly, an instrument may be treated as debt in one country
See MoreUS Tax Cuts and Jobs Act: Base Erosion Minimum Tax
The Tax Cuts and Jobs Act provides for a participation exemption in the form of a 100% deduction for the foreign-source portion of dividends received from 10%-owned foreign corporations. This deduction for dividends received can eliminate additional
See MoreDenmark publishes updated threshold tables for corporate tax purposes for 2018
Rrecently, the Danish Ministry of Taxation has published updated threshold tables for corporate tax purposes for 2018. For corporate tax purposes, the only change is an increase in the carried forward loss offset limit from DKK 8.025 million to DKK
See MoreRomania: Ordinance amending the Tax Code published
In the Official Gazette no. 885 of 10 November 2017, Emergency Ordinance no. 79 concerning the modification and completion of Law no. 227/2015 regarding the Tax Code has been published by the Romanian Government. According to the new rule a taxpayer
See MoreNorway: Government publishes tax proposal in Budget 2018
On 12 October 2017, the Norwegian Government published its proposal for the 2018 Fiscal Budget. The following tax measures are proposed in the Budget. The government has proposed to reduce the general corporate tax rate from 24% to 23% with
See MoreNetherlands: The new Dutch Government publishes Policy Paper
The new Dutch government published its Policy Paper on 10th October 2017. The paper highlights the policy of the new Dutch government for the next four years. The new four-party coalition government was formed after extensive negotiations after the
See MoreSaudi Arabia: Royal Decree on amendment to the Income tax law issued
The government of Saudi Arabia issued Royal Decree No. M/131 on 20 September 2017 modifying certain articles of the Income Tax Law (ITL). The most important amendments brought by the Royal Decree are as follows: -Shares in domestic corporations held
See MoreMalta to introduce equity funding deduction
On 5 October 2017 Malta published rules for a notional interest deduction on equity funding. The underlying idea is to align the tax cost of debt funding with that of equity - if the taxpayer so chooses, since the deduction will be optional. The
See MoreIreland: Budget for 2018
On 10 October 2017, the Irish government presented details of the Budget 2018. This budget delivers the Government’s long standing target of balancing the books in structural terms next year by reaching the Medium Term Budgetary Objective better
See MoreColombia changes rules of amortization of intangible assets
Colombian National Tax Authority (DIAN) has published a ruling regarding the application of amortization of intangible assets. In accordance with ruling, amortization method of an intangible must be decided based on the accounting rules, as long as
See MoreMalta amendments fringe benefits rules
On 8 August 2017, the Minister for Finance (MoF) made amendments to Fringe Benefits Rules and Inland Revenue Department published a guide to provide explanations and instructions on the application of the Fringe Benefits Rules (SL 123.55). It
See MoreBelgium: Details Budget for 2018
On 26 July 2017, the federal government of Belgium announced a major tax reform for the 2018 budget. The reform will take place in two steps, in 2018 and 2020 along with several major changes. Corporate income tax rate The rate of corporate income
See MoreChina plans to boost up foreign investment
China is striving to become more inviting to FDI and foreign talent by widening market access and improving the business environment. On 28 July 2017, the decision was made at a State Council executive meeting presided over by Premier Li
See MoreUK: Draft guidance on corporate tax loss relief rules
On 31 July 2017 HMRC issued for public consultation draft guidance in relation to the reform to corporate tax loss relief rules. An amended draft of the relevant legislation on corporation tax loss relief was published on 13 July 2017 and this is to
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