Taiwan releases tax ruling regarding calculating Taiwan-sourced income of foreign entities
The Ministry of Finance released a tax ruling regarding the new method of calculating income source from Taiwan originating from foreign companies that import, store, manufacture and deliver goods to domestic and foreign customers. According to the
See MoreAustralia: Federal Budget 2018
On 8 May 2018, the Commonwealth Treasurer, Mr. Scott Morrison, announced the Federal Budget 2018-19. Mr. Morrison said “in this year's Budget there are five things we must do to further strengthen our economy to guarantee the essentials
See MoreSweden: The Draft legislation regarding corporate tax changes submits to the parliament
On 3 May 2018, the draft law was submitted to the Swedish Parliament for the introduction of new tax rules for the corporate sector. The proposal comprises new rules on re interest deductions, financial leasing and a reduced corporate tax rate. The
See MoreChina introduces 7 tax cuts
On 25 April 2018, Chinese Ministry of Finance has declared 7 key measures to support SMEs and innovation. The measures include: Enterprises’ new purchase of R&D equipment worth less than RMB 5 million can be deducted for one time before
See MoreNigeria: President accepts VAIDS deadline extension until 30 June
The President, Muhammadu Buhari, has approved the extension of the Voluntary Assets and Income Declaration Scheme (VAIDS) to June 30, 2018 from March 31, 2018. Note that, no further extension of time will be approved after June 30, 2018. The VAIDS
See MoreChile: Tax authority issues Ordinances for describing dual corporate tax regimes
The tax authority has published Ordinance 470 and Ordinance 471 of 5 March 2018. It describes the application of the dual corporate tax regimes introduced as of January 1, 2017. These regimes are the standard attribution regime (AIS regime) and the
See MoreBelgium: Constitutional Court announces the fairness tax unconstitutional
On 1 March 2018, The Constitutional Court of Belgium announced the fairness tax unconstitutional, thus nullifying it (judgment n° 24/2018). According to the Court’s ruling, however, the fairness tax is maintained until financial year 2017 (tax
See MoreRussia clarifies the deduction of losses incurred by consolidated group
On 9 March 2018, the Ministry of Finance (MoF) clarified the deduction of losses incurred by consolidated group members. Accordingly, the MoF stated that, under article 278.1(1) of the Tax Code (TC), the tax base of a consolidated group of taxpayers
See MoreSweden: Special rules apply to the taxation of certain shares and interests
Recently, the Swedish Tax Agency published a Guidance (No. 202 466593-17/111) provides that dividends and capital gains on unlisted shares in a foreign legal person are taxed at a reduced rate only if the taxpayer is a tax resident. Special rules
See MoreUS: President signs Tax Cuts and Jobs Act
Congress has passed the Tax Cuts and Jobs Act(the Act), and the President signed it on December 22, 2017. The most important changes in the area of corporate taxation are: Main corporate tax rate: Under the new Act, the corporate tax rate
See MoreCroatia: Tax reforms effect from 1 January 2018
With effects from January 1, 2018, some tax law amendments have occurred in Croatia. These amendments contain tax laws, excise duties, reliefs etc.. The Minister of Finance issued the Ordinance on Amendments to the Ordinance on Profit Tax, which
See MoreAngola: Parliament approves draft law on tax and foreign exchange compliance
Recently, Parliament approved a bill on the extraordinary tax and foreign exchange regime that regulates the repatriation of assets held abroad that were not declared in Angola in December 2017. All Angolan nationals residing in the country and
See MoreBelgium: Corporate tax reform beginning from 2020
On 29 December 2017, The Belgian corporate tax reform law was published in the official gazette contains measures that will be effective as from tax periods beginning from 1 January 2020. Corporate income tax rate reduction The corporate income tax
See MoreUS: 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
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