Hong Kong issues practice note in the methodology for attributing profits to PEs
On 19 July 2019, the Inland Revenue Department (IRD) released Departmental Interpretation and Practice Note 60 (DIPN 60) which explains the concept of permanent establishment (PE) and the methodology for attributing profits to Hong Kong
See MoreBolivia issues resolution for tax certificates procedure
On 29 June 2019, Bolivian National Tax Service issued Resolution No. 101900000011 in the official website introducing procedure and requirement for certificates of tax residence, tax debt, and foreign accreditation. The resolution clarifies the
See MoreBangladesh enacts Budget for 2019-20
On 30 June 2019, Parliament passed the Tk 5,23,190 crore national budget for 2019-20 fiscal year. The proposals were enacted by the Finance Act, 2019 (the Act) and became effective as of 1 July 2019. The summary of key amendments introduced by
See MoreVietnam: NA approves a new taxation regime for Foreign Service providers
On 13 June 2019, the National Assembly (NA) approved the Law on Tax Administration (amended changes). The law introduced a new taxation regime for Foreign Service providers including e-commerce business. This law will take effect from 1 July
See MorePakistan presents Budget for FY 2019-20
On 11 June 2019, the Finance Minister has presented the budget for the financial year (FY)2019/2020 to the parliament. The finance minister said that the total federal revenue was estimated at Rp6.717 trillion, 19% more than the previous year's
See MorePortugal legislates the EU ATAD into domestic law
On 3 May 2019, Portugal published Law n. 32/2019 in the Official Journal which introduced amendments to the Portuguese Tax Law in line with the European Union (EU) Anti-Tax Avoidance Directive (ATAD) provisions. The law amends the following
See MoreIndonesia: MOF publishes regulations on permanent establishment’s rules
On 1 April 2019, the Minister of Finance (MoF) of Indonesia Published Regulation No. 35 / PMK.03 / 2019, on what constitutes a permanent establishment (PE).The main measures contain that are: According to the Regulation (PMK-35), the following
See MoreIndia: CBDT invites public comments on proposal to amend rules for profit attribution to PE
On 18 April 2019, the Central Board of Direct Taxes (CBDT) released the Committee’s report on profit attribution to a permanent establishment (PE) in India for public consultation, specifically requesting for comments on the conclusions and
See MoreUkraine: SFS clarifies controlled transactions between a non-resident and its PE in Ukraine
On 19 April 2019, the State Fiscal Service (SFS) of Ukraine published a guidance letter 1723/6/99-99-15-02-02-15/IPK on the treatment of transactions between a non-resident and its permanent establishment (PE) in Ukraine as controlled for transfer
See MoreGreece revises the law on setting up branches with new incentives
On 1 April 2019, the Greek Parliament passed a new bill (Law 4605/2019 ) which includes amendments to Law 89/1967 on the establishment of branches in Greece by foreign companies, including in relation to allowed business activities and incentives
See MoreIndia: ITAT ruled that the income which is deemed to accrue or arise in India must have a territorial nexus
Recently, the Mumbai Bench of the Income-tax Appellate Tribunal (ITAT) in the case of: Fox International Channel Asia Pacific Ltd v. DCIT (ITA No.1947/Mum/2015) regarding the taxability of agency commission relating to the services rendered outside
See MoreLuxembourg: Tax Authority clarifies the new Permanent Establishment definition
On 22 February 2019, Luxembourg tax authorities issued a new circular (No.19) that clarifies recently added the new Permanent Establishment (PE) definition as set forth in article 16(5) of the Tax Adaptation Law (StAnpG). Under the new paragraph,
See MoreCosta Rica: MOF publishes resolution on tax residence certificates
On 19 February 2019, Costa Rica's Ministry of Finance (MOF) published a Resolution (was first published in the Official Gazette on 4 February 2019), which provides rules on the determination of tax residence and the issuance of residence
See MoreArgentina releases decree regarding tax reform measures for corporations
On 27 December 2018, Argentina published a Regulatory Decree 1170/2018 in the Official Journal, which entered into force on 28 December 2018. The decree prescribes policy changes to Law 27,430 of 2017, which introduced tax reform measures for 2018.
See MoreFrance: Parliament legislates the Finance Act for 2019
The French Finance Act passed its constitutional review for 2019 on 28 December 2018. This follows the approval of the law by Parliament on 20 December 2018. The main measures of the law are summarized as follows: Corporate Income tax rate:
See MoreQatar legislates new Income Tax Law
On 17 January 2019, Qatar's new Income Tax Law (Law 24 of 2018) was published in the Official Gazette and replaced the previous Law 21 of 2009, and is effective from 13 December 2018. The main features of the new law are summarized in below: The
See MorePuerto Rico enacts the tax reform law
On 10 December 2018, Puerto Rico enacted Bill No. 1544 as Law No. 257 of 10 December 2018. The law includes numerous amendments to the Puerto Rico Internal Revenue Code of 2011 (PR Code). The changes are to generally apply for periods beginning
See MoreColombia legislates the tax reform Bill for 2019
Colombia enacted tax reform (Law 1943-Tax Reform) on 28 December 2018. The Tax Reform makes numerous changes to the Colombian tax rules that generally apply from 1 January 2019. The tax reform includes following changes: Corporate tax: The Tax
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