Ireland: Revenue provides guidance on foreign entity classification for Irish tax purposes
On 18 May 2023, the Irish Revenue issued eBrief No. 117/23 to provide guidance on classifying foreign entities for Irish tax purposes. Accordingly, Revenue provides Tax and Duty Manual (TDM) Part 35C-00-02 - Foreign Entity Classification For Irish
See MoreIMF Report Looks at the Economy of Hong Kong SAR
On 8 March 2022, the IMF published a report following discussions with the Hong Kong Special Administrative Region (SAR) of China, under Article IV of the IMF’s articles of agreement. The economy of Hong Kong SAR has undergone a strong
See MoreRussia proposes Tax Policy for 2020 to 2022
On 30 September 2019, the Russian Government submitted the Draft Law to the State Duma. The draft law includes the following measures: The bill aims to change the approach to taxing companies in the digital sector. The draft law recommend that
See MoreTaiwan: MOF issues tax ruling on Taiwan-sourced income of foreign entities
On 26 September 2019, Taiwan’s Ministry of Finance (MOF) released a tax ruling regarding the new method of calculating income source from Taiwan originating from foreign entities amending article 15-1 in accordance with Article 8 of the Income
See MoreSouth 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 MoreWorld Bank approves grant to improve domestic revenue mobilization in Liberia
On 16 July 2019 the World Bank approved a grant to its International Development Association (IDA) to improve domestic revenue mobilization systems and strengthen financial control and accountability in public finances. The IDA provides grants and
See MoreTaiwan 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 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 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 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: 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 MoreUruguay: Executive Power formally proposes accountability bill 2016
The Executive Power of Uruguay submitted to Congress for consideration the 2016 Accountability Bill on 20 June 2017. The Bill includes provisions on Internet services and the software industry. The bill would also modify the Free Zones (FZ) law. If
See MoreKorea: Recent developments on corporate taxation
With the aim of encouraging the development of new growth-engine industries, reinforcing employment-friendly tax schemes, and facilitating corporate restructuring, a few amendments that affect foreign investment or foreign invested companies have
See MoreNigeria: New tax amnesty scheme in force
According to an announcement from the Finance Ministry, a new tax amnesty called the Voluntary Assets and Income Declaration Scheme (VAIDS), entered into force on July 1, 2017 for both individuals and corporations. The amnesty aims to raise tax
See MoreUruguay- Fiscal Transparency Law issued
Uruguay has issued Decree 77/2017 as a guide to Law No 19.484 which sets out the provisions on compliance with international standards for fiscal transparency. The Decree clarifies which companies are required to provide the tax authorities with
See MoreArgentina: Amendments and clarification in tax amnesty regime
A Decree 1,206/2016 was published in the Official Gazette of 30th November 2016 and effective from 1st December 2016. This decree amends and clarifies certain aspects of the tax amnesty regime implemented by Decree 895/2016. The main requirements
See MoreCroatia: Proposal for corporate income tax amendments
The Tax Administration has presented proposed changes to the Corporate Income Tax Law (CIT law) on 4th November 2016. The significant elements are summarized below: Tax Base The tax base of corporate income tax will be extended by introduction of
See MoreUkraine: Draft law proposed to introduce thin capitalization rules
Draft law No. 3357 on amending the Tax Code of Ukraine regarding tax liberalization was registered in the Ukrainian parliament on October 26, 2015. The draft law have proposed several tax measure including thin capitalization rules and distributed
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