Russia: 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 MoreColombia: Tax reform summary 2016
According to law 1819 of 2016, adopting the structural tax reform bill approved on 23 December 2016. It introduces the following major changes to the corporate income tax regime: Income tax rates As from tax year 2019, a single income tax rate of
See MoreSlovenia: Publishes advance pricing agreement rules
Details on the introduction of Advance Pricing Arrangements (APAs) are now available in the Official Gazette on 28 December 2016. Accordingly, the following rules will apply from January 2017: (i) The application of APA must be addressed to the
See MoreBulgaria: Updated list of tax havens published
The Finance Ministry has published an Order No. ZMF-1303 on 21st December 2016 regarding an updated tax haven list. This list applies from 29th December 2016 contains the following countries: Antigua and Barbuda, the Bahamas, Brunei, Christmas
See MoreDenmark: 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
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