Denmark: CJEU decision regarding exemption for interest income
The Court of Justice of the European Union (CJEU) on 21 December 2016, published a judgment in the case of:Masco Denmark and Damixa about the Danish corporate tax rules that provide an exemption from tax for interest income on loans provided by a
See MoreTaiwan: Finance Minister publishes draft rules on CFC and PEM
Finance Minister issued draft regulations on a controlled foreign company (CFC) and place of effective management commenced in July 2016 on 9 November 2016. The draft regulations intend to explain CFC income’s timing and amount addition CFC
See MoreJapan: Amendments coming for CFC rules in 2017 tax reform
Japan's tax commission has announced on 8 December 2016, its intention to amend the tax rules regulating CFCs (controlled foreign corporations), which are also known as the Anti-Tax Haven Rules. According to the proposed 2017 tax reform, the
See MoreDenmark: Issues CbC notification rules
The Danish tax authorities (SKAT) on 9 December 2016 announced that country-by-country (CbC) notifications must be submitted electronically and in a standardised format on Form 05.034. The form contains instructions both in English and Danish, and
See MoreBrazil: Updates fictitious credit for CFC rule
Normative Instruction 1,674/2016 released in the official Gazette on 29 November 2016 and in force on the same date of publishing. Normative Instruction 1,674/2016 adjusts the option that, resident companies to submit the profits derived by the
See MoreBulgaria: Transfer pricing regulations
Bulgaria fully follows and applies the OECD Transfer Pricing (TP) guidelines and has had robust TP rules for several years, but taxpayers must be concerned about the regulations. The TP rules were first announced in the Corporate Income Tax Act
See MoreColombia: Tax reform bill 2016
The comprehensive tax reform bill 2016 recently submitted by the government of Colombia to the Congress with the following corporate income tax issues: Rates: The bill proposes to unify the income tax and the Fairness Tax into a single income tax
See MorePoland: Publishes amended bill on CIT exemption for investment funds
The first reading of the draft Bill on the amendment of the Corporate Income Tax Act, which was submitted to the Parliament on 31 October 2016, took place in the Parliament on 4 November 2016. According to the bill, withdrew the full exemption
See MoreVietnam: Publishes the draft decree on transfer pricing
The final draft transfer pricing (TP) decree was released on 3 October 2016 by the Ministry of Finance, following Resolution No. 19-2016/NQ-CP dated 28 April 2016. The decree aims to replace the existing TP regulations, Circular 66/2010/TT-BTC, and
See MoreNigeria: Draft revised national tax policy
The Federal Inland Revenue Service (FIRS) has published a public notice on 11th November 2016, which was issued by the Finance Ministry on the stakeholders' forum. This forum had been convened from 7th to 8th November 2016 to discuss the draft
See MorePoland: Parliament adopts budget Law for 2017
The Council of Ministers presented to the parliament a draft Budget Law for 2017 on 30 September 2016. All along with the introduction of tax changes, different numbers of factors that have into force on budget revenues are envisaged. Corporate
See MorePoland: Approves the general anti- avoidance rule into the Polish Tax Law
Polish President approved a draft legislation introducing a general ant avoidance rule (GAAR) into the Polish Tax Law. On June 14, 2016, the clause was published in the official Journal of Laws and came into force as of July 15, 2016. GAAR shall
See MoreItaly: Publishes new guidance on CFC regulations
The Italian Tax Authorities issued Protocol No. 143239 (the Protocol) on 16 September 2016, providing further clarifications on CFC legislation, as recently amended by Legislative Decree No. 147 of 14 September 2015 and Law No. 208 of 28 December
See MoreBrazil: Decision releases concerning the application of the new Brazilian CFC rules
The Federal Court of Curitiba passed on a decision in relation to Process No. 5005596- 52.2015.4.04.7000/PR on May 6, 2016.The single court judgments finish off that a Brazilian taxpayer may remove from the calculation of its corporate income tax
See MoreTurkey: Amendment in transfer pricing legislation
The Law No. 6728 on the amendment of certain laws for the improvement of the investment landscape has been published in the Official Gazette on 9 August 2016. This law amended certain transfer pricing provisions. Some of the provisions are given
See MoreWTO backs Argentina’s anti-avoidance tax measures
The Appellate Body of the World Trade Organization (WTO) provided its report on 14 April 2016, regarding "Argentina – Measures relating to trade in goods and services" case brought by Panama. In the case concerned, and in relation to Argentina's
See MoreRussia: Notification of tax authorities concerning CFCs
The Finance Ministry (MoF) has issued a Letter No. 03-01-23/30779 on 27th May 2016 for clarifying the responsibility of taxpayers to notify the tax authorities about CFCs. On the basis of section 3.1 of article 23 of the Tax Code, taxpayers have to
See MoreIndia: CBDT amends rules relating to GAAR effective date
The Central Board of Direct Taxes (CBDT) issued Notification No. 49/2016 (the Notification) dated 22 June 2016 on the effective date of the general anti-avoidance rules (GAAR). According to the Notification, the amendments to the Income Tax Rules,
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