UK: Main 2017 tax changes affecting corporation tax
The budget insert for the CT600 company tax return, initially issued in March 2017, has been updated to include further information on changes affecting the return. The changes cover announcements made in the 2016 Autumn Statement and measures in
See MoreUK: HMRC is seeking comments on pending corporate interest restriction rules
On 4 August 2017, UK HM Revenue and Customs (HMRC) published a second draft guidance for public comments on pending corporate interest restriction rules. An initial tranche of draft guidance was published on 31 March 2017. This second tranche of
See MoreUK: Timetable for Finance Bill (No. 2) 2017
According to an announcement of 20 July 2017 in Hansard the Ways and Means Resolutions relating to the Finance Bill (No. 2) 2017 are to be submitted to the House of Commons for approval on 6 September 2017. The Bill is expected to be published
See MoreIMF deputy managing director comments on tax and economic growth in Asia
On 12 July 2017 the IMF Deputy Managing Director Mitsuhiro Furusawa, speaking in Indonesia, commented on the importance of international tax developments for economic growth in Asia. He stressed the importance of revenue mobilization and
See MoreFrance: CJEU rules on 3% contribution on distributed profits
In France, companies subject to Corporate Income Tax (CIT) are required to pay an additional CIT contribution of 3% on the distributed profits according to article 235 ter ZCA of the French general tax law. But, the Court of Justice of the European
See MoreNorway: Exemption from withholding tax applies
The tax authorities released a "binding advance ruling" (BFU / 17, 4 May 2017) regarding 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
See MoreIndia: Section 14A is subject to dividend income tax regardless of dividend distribution tax (DDT) Payment
Section 14A of the Income Tax Act, 1961 (Act) provides for disallowance of expenditure incurred in relation to income which is not included in the total income of the assessee. The Supreme Court of India in the case of Godrej & Boyce
See MoreGreece: Guidance for company re-organizations
Guidance regarding tax rules through Circular POL 1057/2017 have been issued by the Public Revenue Authority. The guidelines clarify the rules on restructuring in relation to the different types of company at a domestic or EU cross-border level,
See MoreSaudi Arabia- Regulations for implementation of Zakat issued
The Tax Authority of Saudi Arabia issued the Regulations for implementation of Zakat under Ministerial Resolution No. 2082 of 28 February 2017 (01/06/1438H) on 9 March 2017, The regulations applies to all commercial activities established for
See MoreRussia: Clarifies the taxation of CFC profits in determining the corporate tax base of a consolidated tax group
The Ministry of Finance (MoF) on 3 March 2017, published Guidance Letter No. 03-12-11/3/5790 of 3 February 2017, clarifying the taxation of CFC profits in determining the corporate tax base of a consolidated tax group (CTG). According to article
See MoreRussia: Clarifications on carry-forward of CFC losses
The Ministry of Finance (MoF) issued Guidance Letter No. 03-04-05/5577(2 February 2017), clarifying the issue of losses incurred by a controlled foreign company (CFC) on 7 March 2017. The Ministry of Finance identified that, under Article 25.15,
See MoreColombia: Key changes on international mergers and spin-offs
According to a recently published Ruling 2242 of 2017, the Colombian National Tax Authority (DIAN) pronounced on the tax effects of international mergers and spin-offs. In accordance with article 319-8 of the Tax Code (TC), the transfer of assets
See MoreCyprus: Cyprus: Tax Authority abolishes minimum margins on loans effective from 1 July 2017
The Cypriot Tax Authorities (CTA) has announced their intention of withdrawing the Minimum Margin scheme (the MMS) with effect 1 July 2017. It is being reminded that in accordance with Article 33 of the Cyprus Income Tax Law, all transactions
See MoreNetherlands: Updated decree publishes on implication of participation exemption
Decree No. BLKB2016/803M dated 20 January 2017 has been published in Official Gazette No. 5003 on 23 February 2017 regarding implication of the exemption from the participation. The Decree updated and replaced the Decree No. DGB2010/2154M of 12 July
See MoreItaly: Detail corporate tax measures mentioned in Budget Law for 2017
The Italian Budget Law for 2017 entered into force on 1 January 2017. From 2017 financial year, the Italian corporate income tax ("CIT") standard rate is reduced from 27.5% to 24 %. However, Banks, parent companies of banking groups, individual
See MoreChina: Clarifications on enterprise income tax published by SAT
On 9 December 2016, the State Administration of Taxation (SAT) issued an announcement clarifying two issues concerning enterprise income tax. The announcement applies to 2016 and subsequent years. The clarification contains payment of accident
See MoreSaudi Arabia-new requirements regarding tax and zakat returns of Saudi listed companies
The General Authority for Zakat and Tax (GAZT) of Saudi Arabia published Circular Number 6768/16/1438 (the Circular) on 4 December 2016 (5/3/1438H) according to which Saudi listed companies are now required to pay tax and zakat based on the
See MoreFrance-amending Finance Bill for 2016
The Amending Finance Bill for 2016 (projet de loi de finances rectificative pour 2016, PLFR) (the Bill) was presented by the government and submitted to the National Assembly on 18 November 2016. The Ministry of Finance of France announced to
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