Australia: 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 MorePakistan: Finance Minister presents the budget for 2017/2018
On 27 April 2018, the newly-appointed Finance Minister Miftah Ismail presented the 2018/2019 Budget to parliament. The following corporate tax measures are proposed in the Budget: Reduction in corporate tax rates: Reduce the corporate tax rates
See MoreZambia: Government publishes new transfer pricing regulations
Zambia published the income tax (transfer pricing) (Amendment) regulations under Statutory Instrument No. 24 of 2018 in the official gazette on 6th April 2018. The 2018 regulations conduct transfer pricing transactions between related entities as
See MoreColombia issues ruling of CFC exemption
The tax authority of Colombia (DIAN) published a ruling regarding whether the exemption for controlled foreign company (CFC) dividend income paid out of profits from real economic activities will apply if the dividends are paid by a subsidiary of a
See MoreAustria: MOF publishes a draft bill for 2018
On 9 April 2018, the Ministry of Finance (MOF) provided a draft bill for an Annual Tax Act 2018 and submitted it for final consideration. With this draft, the EU Anti-Tax Avoidance Directive (ATAD) will be implemented in Austrian domestic law and in
See MoreSouth Africa: SARS extends CFCs reporting rules to June
Recently, the South African Revenue Service has declared that it will temporarily allow taxpayers to report information on controlled foreign companies (CFCs) under the old filing rules, which were replaced in February From 1 June 2018 all taxpayers
See MoreItaly: launches public consultation regarding implementation measures for transfer pricing provisions
The Italian Ministry of Economy and Finance launched a public consultation on the implementation measures associated with the application of domestic transfer pricing provisions on 21 February 2018. The main purpose of the Draft Decree (supported by
See MoreSingapore: New transfer pricing rules
Singapore Inland Revenue Authority published transfer pricing documentation rules and transfer pricing guidelines in February 2018. The major expansions of the transfer pricing rules are as follows: The arm’s length principle is aligned with
See MoreIndian APA accepts customs valuation as arm’s length price for transfer pricing
Recently, the Central Board of Direct Taxes (CBDT) has entered into an advance pricing agreement (APA) where the price determined by the Indian Customs authorities was accepted as arm’s length price for import transactions for transfer pricing
See MoreBelgium introduces CFC rules and 100% participation exemption
The Belgian corporate income tax reform decreasing the corporate income tax rate to 25% by 2020 (29.58% in 2018 and 2019), also amended a number of measures to increase the attractiveness of Belgium as a holding jurisdiction. Specifically, the
See MoreSouth Africa: Revenue services announces for temporary use of old filing rules
The South African Revenue Service will temporarily permit taxpayers to report information on controlled foreign corporations (CFCs) under the old filing rules replaced in February. SARS replaced the old reporting schedule in February, which was
See MoreDenmark: Government proposes amendments to corporate taxation rules
On 23 February 2018, the Danish Ministry of Taxation published the bill on corporate taxation. The bill amending the Danish company taxation is as follows: Permanent establishment (PE) The Danish government explicitly states that non-Danish
See MoreNetherlands: Dutch Council of Ministers approves fiscal policy agenda
The Council of Ministers approved the fiscal policy agenda on a package to combat tax avoidance and tax evasion. The most important changes are summarized below: Corporate Income Tax (CIT) rate: According to the Agenda, the current standard Dutch
See MoreRussia: MoF clarification on application of thin capitalization rules in the context of tax treaties
Recently, the Ministry of Finance (MoF) issued a Guidance Letter (No. 03-03-06/1/87340) and clarified the application of domestic thin capitalization rules in the context of tax treaties. According to a statement by the MoF, interest paid by a
See MoreNew Zealand: Government drafting amendments to transfer pricing rule
On 14th February 2018 government announced that it will recommend a change to transfer pricing provisions in a bill designed to lessen tax avoidance by multinationals. This bill concerns the new rule to limit the rate of deductible interest on
See MoreCzech Republic: Proposed amendments to income tax for 2019
Recently, Finance Ministry has published the first draft copy of the amendment to the Income Tax Act for comments. These amendments are supposed to be started from year 2019. The proposed personal income tax rate of 19% is 1.1% less than the present
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 MoreSlovak Republic: President approves the Amendments to Income Tax Act
The amendment to Act No. 595/2003 Coll. on Income Tax has signed by the president on 20 December 2017. Most of the amendments entered into force from 1 January 2018. The main changes are summarized here: Definition of permanent establishment The
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