Italy: 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
See MoreCroatia: Tax reforms effect from 1 January 2018
With effects from January 1, 2018, some tax law amendments have occurred in Croatia. These amendments contain tax laws, excise duties, reliefs etc.. The Minister of Finance issued the Ordinance on Amendments to the Ordinance on Profit Tax, which
See MoreMozambique: Council of Ministers approves first transfer pricing regulations
On December 6, 2017, the Council of Ministers has approved the first Transfer Pricing (TP) Regulations by Decree 70/2017. The Decree became in force on or after the January 1, 2018. According to Decree, one company is considered to be related to
See MoreKazakhstan: Tax Law Reforms for the year 2018
The Kazakh President, signed a series of laws on 25 December 2017 regarding taxes and other mandatory payments, introduction of tax code, law on amendments to other Acts etc. Most provisions of the new tax code and the tax amendments effects from 1
See MoreMalaysia enacts Finance (No. 2) Act 2017
The Finance (No. 2) Act 2017 has been published in the Gazette on 29 December 2017, effective as of 1 January 2018. The Act includes certain measures of the 2018 Budget. The law introduces new rules requiring companies to inform the tax authority of
See MoreUkraine: Parliament adopts the amendment to the Tax Code
On 7 December 2017, the Ukrainian Parliament passed the Law of Ukraine "On Amendments to the Tax Code of Ukraine and Certain Laws of Ukraine on Securing Balance of Budget Revenues in 2018” No. 2245-VIII (“Law”). The law came into force on 1
See MoreArgentina: Comprehensive tax reform enacts
The Law No. 27430 or comprehensive tax reform was published on December 29, 2017 in the Official Gazette and it generally applies from January 1, 2018. This comprehensive tax reform bill has sent to Congress on December 14, 2017. The Ministry of the
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