Thailand: Consultation process of the draft Transfer Pricing rules
The Revenue Department of Thailand is requesting public comments with respect to the Draft Transfer Pricing Rules which were approved by the Thai Cabinet on May 2015. The comments are to be provided by 7 July 2017. Recently, the draft measures were
See MoreSlovak Republic: Government declares new corporate tax measures
The Government announced several changes in the corporate taxation area on 20th June 2017, including the introduction of a new patent box regime in line with the modified nexus approach developed as part of BEPS Action 5. The government also
See MoreTaiwan: Draft amendment to controlled foreign company rules issued
Taiwan’s Ministry of Finance issued Ruling No. 10604557490 on 6 June 2017, providing clarification to the proposed controlled foreign company (CFC) regulations which was issued on 9 November 2016. According to the proposed CFC rules, Taiwanese
See MoreColombia: Tax reform 2016 amends, new CFC rules
On 5 June 2017, the government of Colombia published Decree 939 of 2017 that removed previous errors of articles 89, 99, 111, 123, 165, 180, 281, 289, 305, 317 and 319 of Law 1819 of 2016. In accordance with Law 1819, there are multiple provisions
See MoreItaly: Decree issued on urgent measures on tax matters
The Council of Ministers of Italy enacted a Law Decree No.50 with an effort to meet the European Union (EU) demands of extra budget deficit cuts. The Decree was published in the Official Gazette on 24 April 2017 and provides urgent measures on tax
See MoreCzech Republic: MoF issues a paper on anti-tax avoidance rules
The Finance Ministry published on its website a discussion paper regarding the implementation of EU Anti-Tax Avoidance Directive on 12th of July 2016. The directive mainly states new rules for interest deduction restrictions and similar expenses
See MoreIndia: Finance Bill 2017 passed by the Lower House of Parliament
The Lower House of Parliament (Lok Sabha) passed the Finance Bill 2017 on 22 March 2017. The key amendments to the Finance Bill 2017 are discussed below: Proposed section 94B of the Income Tax Act, 1961 (ITA) limiting the deduction of interest
See MoreCanada: The Federal Budget 2017 announced
The Canadian government presented the 2017 federal budget on 22nd March 2017 in Ottawa. The main highlighting points of this budget are given below: The budget dedicates $11.2 billion to cities and provinces for affordable housing over 10 years
See MoreVietnam: Recently released a new transfer pricing decree
Vietnam’s Government has recently released a Transfer Pricing (“TP”) Decree No. 20/2017/ND-CP on 24 February 2017, provided that tax administration applicable to enterprises having controlled transactions’ (Decree 20), which will take effect
See MoreBrazilian CFC rules apply despite treaties
The Federal Administrative Council of Tax Appeals (Conselho Administrativo de Recursos Fiscais, CARF) decided on 14 March 2017 that taxation in Brazil of profits of indirect controlled foreign companies (CFCs) under CFC rules is not prevented by tax
See MoreSerbia: Ministry of Finance publishes rulebook on arm’s length interest rates for 2017
The Serbian Ministry of Finance adopted the amendments to the Rulebook on arm's length interest rates (the Rulebook) on 10 March 2017. The rulebook contains the prescribed interest rates for taxpayers who had or will have related-party financing
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 MoreIndia: Related-party Relationship Upheld by The Tribunal
Recently, the Chennai Bench of the Income-tax Appellate Tribunal (the Tribunal) in the case of: Hospira Healthcare India Private Limited v. DCIT (ITA No. 821/Mds/2016 - AY 2011-12), held that under a provision of India’s tax law, “influence”
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 MoreChile: Tax Administration replies first query regarding GAAR
The Tax Administration has released Administrative Jurisprudence No. 261/2017 on 3rd February 2017 on its website. This addresses for the first time a query regarding the application or non-application of the general anti-avoidance rule (GAAR)
See MoreIndia: Proposes amendments to the transfer pricing regulations
Indian Finance Minister published India’s 2017-18 budget on 1 February 2017. Along with other measures, the budget has proposed following important amendments to the provisions of transfer pricing (TP) regulations of India: –A major proposal in
See MoreSingapore: IRS publishes Transfer pricing guidelines 2017
The Inland Revenue Authority of Singapore published the 4th version of transfer pricing guidelines on 12 January 2017, demonstrating compliance with international transfer pricing standards. The published guidelines explicitly refer to the Base
See MoreIndia announces GAAR will be effective from April 1, 2017
On 27 January 2017, the CBDT has issued Circular No. 7 of 2017 and provided important clarifications on the implementation of GAAR which are to come into force from 1 April 2017. The Circular provides clarifications, considering the comments of the
See More