Germany: Capital gains 100% tax-exempt for foreign corporate shareholders
On 25 October 2017, the German Federal Tax Court (decision dated 31 May 2017) ruled in favor of foreign shareholders selling shares in a German corporation. Capital gains realized upon sale of shares in a German resident corporation by non-resident
See MoreDutch government contingency plans to restrict domestic tax consolidation
On 25 October 2017 the Dutch government announced emergency measures to prevent the Dutch tax consolidation rules being used in international tax avoidance structures. The measures are a direct response to ongoing litigation before the EU Court of
See MoreUS: Tax reform bill published
The long awaited US tax reform bill was released by House Republicans on 3 November 2017. The impact on the deficit is estimated at $1.5tn over 10 years. The corporate tax rate would be reduced from the current 35% down to just 20% starting in 2018.
See MoreMorocco: Draft Budget for 2018
The draft budget 2018 was presented to the Parliament on October 20, 2017. This draft Law is available in French language. The Economic and Finance Minister, Mr. Mohamed Boussaid, held a press conference regarding the Finance Bill 2018 on October
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 MoreFrance: Draft finance bill for 2018 released
The government of France released the draft Finance Bill for 2018 on 27 September 2017. The main changes outlined in the draft Bill are as follows: Decrease of the French corporate income tax rate Elimination of the 3% tax on dividend
See MoreHong Kong adopts a new intragroup tax loss transfer regime
According a proposal from high level government advisory panel, Hong Kong adopts a new intragroup tax loss transfer regime. If adopted, these new tax rules would have significant impact on business and investment decision-making in Hong Kong,
See MoreAustralia: Consultation on Consolidation Integrity Measures
On 11 September 2017, the Minister for Revenue and Financial Services released draft tax consolidation legislation and an explanatory memorandum for public consultation. These important measures restore integrity to the tax consolidation rules. The
See MoreUK: 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
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