Slovak 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 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 MoreItaly: Approves budget Law for 2018
The Italian Budget Law for 2018 (Law no. 205 of 27 December 2017) published on 29 December 2017 and entered into force on 1 January 2018. Some of its most significant corporate tax measures are summarized below: Dividends: Dividends from
See MoreJapan issues tax reform plan for 2018
The ruling Liberal Democratic Party of Japan accepted a tax reform package on 14 December 2017. Based on the draft, a tax reform bill (The Bill) will be drafted. The bill will be submitted to Parliament and is expected to enter into force by the end
See MoreNew Zealand: A tax bill to counter tax avoidance introduces into Parliament
On 6 December 2017, a tax bill to counter tax avoidance has been introduced into New Zealand’s Parliament by multinational companies and Minister of Revenue also published its commentary on the bill. Most provisions would enter into effect July
See MoreItaly: Updates definition of permanent establishment
The Italian Senate approved the draft Budget Law for 2018 on 30 November 2017. The draft illustrated the definition of the domestic permanent establishment (PE) as per the definition proposed by the OECD in the BEPS Action 7 Final Report. The draft
See MoreNorway: Government publishes tax proposal in Budget 2018
On 12 October 2017, the Norwegian Government published its proposal for the 2018 Fiscal Budget. The following tax measures are proposed in the Budget. The government has proposed to reduce the general corporate tax rate from 24% to 23% with
See MoreIndia: Clarification guidelines for establishing place of effective management
The Central Board of Direct Taxes recently issued a circular (No. 25 of 2017) on 23 October 2017. This circular clarifies that, as long as the regional headquarter operates for subsidiaries/group companies in a region, within the general and
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 MoreGuernsey: The Beneficial Ownership of Legal Persons Law enacted
The Beneficial Ownership of Legal Persons (Guernsey) Law, 2017 came into force on 15 August 2017. The Law establishes the Office of the Registrar of Beneficial Ownership of Legal Persons, sets out the powers and functions of the Registrar, and
See MoreThailand: New tax, legal requirements for representative offices of foreign companies
According to new Thai rule, a foreign company’s representative office in Thailand is no longer obliged to obtain a foreign business license from the Department of Business Development. Though, the representative office is still subject to other
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 MoreIndia: Physical presence in the source state is not necessary to constitute a service PE
A recent decision of the Bengaluru Bench of the Income-tax Appellate Tribunal (Tribunal) in the case of: ABB FZ-LLC v. DCIT [ITA(TP) No. 1103/Bang/2013, assessed the India-UAE (United Arab Emirates) Double Taxation Avoidance Agreement (tax treaty)
See MoreFinland: Tax administration publishes guidance on the allocation of profits to PEs
On 13 June 2017, the Tax Administration published guidance on the allocation of profits to a permanent establishment (PE). A permanent establishment in Finland is liable to Finnish taxation on profits arising in Finland. Permanent establishment
See MoreIndia: CBDT publishes a draft notice on special transitional provisions for a foreign company based in India
The Finance Ministry on 15 June 2017, issued a draft notification of transitional provisions for foreign companies in the first year of becoming resident based on their place of effective management. The notification has clarified that the tax on
See MoreAustralia: Draft Taxation Ruling TR 2017/D2 – Central Management and Control test of residency
The Australian Tax Office has now released a new draft ruling TR 2017/D2 and has withdrawn its preceding ruling TR 2004/15 on the tax residence of foreign incorporated companies. Following the decision in Bywater Investments Limited &
See MoreThailand- new tax on e-commerce to be introduced in April 2017
The Revenue Department of Thailand is planning to enforce a new law to tax cross-border e-commerce transactions by April 2017. Currently, a foreign operator which carries on e-commerce business but does not enter Thailand or does not have any
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