Poland: A new version of a draft bill to amend corporate income tax law
Recently, a new version of a draft bill to amend Poland’s corporate income tax law (and also to amend the individual income tax law) was submitted to the parliament. The amendment will most likely come into effect on 1 January 2018. Main changes
See MoreSlovak Republic: Government approves draft amendments to Income Tax Act
The government approved a bill amending the Income Tax Act on August 16, 2017. A draft amendment of the income tax act highlights the existing measures for the protection against tax fraud, extended of the rules for the protection against aggressive
See MoreZambia: Budget for 2018
Finance Minister of Zambia presented the 2018 National Budget for the year 1 January 2018 to 31 December 2018 to the National Assembly on 29th September 2017. Budget for 2018, which lays out the various expenditure and revenue measures aimed at
See MoreSlovak Republic: Proposed provisions for patent box regime, exit tax, CFC rules
The Government announced several changes in the corporate taxation area on June 20, 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 proposes
See MoreMozambique: Transfer pricing regulations approved
The Council of Ministers approved transfer pricing regulations on September 12, 2017 that present the methods for the assessment of the transfer pricing transactions between related entities. It allows amendments to the taxable profit by the tax
See MoreRussia: Guidance on application of new GAAR
The Federal Tax Service (FTS) on 16 August 2017, issued a Guidance Letter on the application of Russia's new general anti-avoidance rule (GAAR), which was introduced in July 2017. The guidance clarifies that in applying the GAAR the tax authorities
See MoreIndonesia updates CFC rules
The Indonesian Ministry of Finance has updated the Controlled Foreign Company (CFC) rules by issuing Regulation No. PMK-107/PMK.03/2017 on 27 July 2017. The Regulation is effective from same date. Regulation PMK-107/PMK.03/2017 has extended the
See MoreBrazil: Provisional Measure publishes in the official gazette regarding revised CFC rules
On 18th August 2017, Brazil published Provisional Measure No. 795 ("MP No. 795/2017") in the official gazette 2017 regarding revised CFC rules for Brazilian organization. Provisional Measure No. 795/2017 which provides for changes in the tax
See MoreBelgium: Details Budget for 2018
On 26 July 2017, the federal government of Belgium announced a major tax reform for the 2018 budget. The reform will take place in two steps, in 2018 and 2020 along with several major changes. Corporate income tax rate The rate of corporate income
See MoreRussia: New GAAR provisions in the Tax Code
The Russian parliament on 5 July 2017 approved a draft law (no. 529775-6) introducing a new general anti-avoidance rule (GAAR) into the Tax Code. The new law introduces a new Article 54.1 containing a definition of the limitations on the rights
See MoreIndia: Tribunal decision on foreign exchange fluctuation gain or loss and arm’s length pricing
The Income-tax Appellate Tribunal in the case of ACIT v. Rajratna Metal Industries Ltd. held that a foreign exchange fluctuation gain/loss is an operating item and is not to be excluded for the purpose of computing the arm’s length price
See MoreHungary: Introduced new CFC regime
The amendments to the controlled foreign company (CFC) of Hungary were included in a draft bill which was approved by Parliament on 13 December 2016 and published on 19 December 2016. The new CFC regime is broadly in line with the provisions of the
See MorePoland: Ministry of Finance publishes a draft bill on corporate income tax
The Polish Ministry of Finance issued a draft bill on 12th July 2017, regarding corporate income tax. The draft bill proposes significant changes and sets new foundations in taxation rules for companies in Poland. The bill changes the
See MoreJapan: amendments to CFC rules in 2017 tax reform
The 2017 tax reform bills were passed by the 193rd ordinary session of the Japanese National Diet on 27 March 2017. Accordingly, the Japanese regulations on controlled foreign companies (CFC) have been fundamentally revised, taking into account the
See MoreNetherlands: The Dutch government publishes consultation on anti-tax avoidance directive
The State Secretary of Finance provided a letter to Dutch parliament in which he indicated that an internet consultation has been opened for a draft bill on 10th July 2017. The draft bill has been formulating in order to implement the first EU
See MoreThailand: 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
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