Belgium: Details Budget for 2018

August 17, 2017

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

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India: Physical presence in the source state is not necessary to constitute a service PE

July 25, 2017

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)

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Finland: Tax administration publishes guidance on the allocation of profits to PEs

July 17, 2017

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

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India: CBDT publishes a draft notice on special transitional provisions for a foreign company based in India

June 19, 2017

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

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Australia: Draft Taxation Ruling TR 2017/D2 – Central Management and Control test of residency

May 15, 2017

The Australian Tax Office has now released a new draft ruling TR 2017/D2 and has withdrawn its preceding ruling TR 2004/15 on the tax residence of foreign incorporated companies.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 &

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Thailand- new tax on e-commerce to be introduced in April 2017

April 28, 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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Canada: The Federal Budget 2017 announced

March 23, 2017

The Canadian government presented the 2017 federal budget on 22nd March 2017 in Ottawa. The main highlighting points of this budget are given below: The budget dedicates $11.2 billion to cities and provinces for affordable housing over 10 years

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Norway proposes new corporate residency rules

March 21, 2017

The Finance Minister opened a public hearing regarding the corporate tax residency rules under section 2-2 of the Tax Law (Skatteloven) on 16 March 2017. There is no definition of residence is available now in the Norwegian tax legislation for legal

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India: Clarification on determination of POEM provision

February 28, 2017

The Central Board of Direct Taxes (CBDT) has issued Circular No. 8/2017 of 23 February 2017 clarifying that the existing provisions in place of effective management (POEM) will not apply to a company with a turnover or gross receipts of INR 500

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India: CBDT Publishes draft guidelines for determination of the POEM

January 26, 2017

The Central Board of Direct Taxes (CBDT) on 24 January 2017, has issued the guiding principles to be followed for determination of the place of effective management of a company (POEM). The concept of PoEM for deciding the residential status of a

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Sweden: Administrative Court rules PE exists in Sweden due to regular nature of activities

January 23, 2017

The Swedish Administrative Court of Appeal in the case of: Gothenburg (Kammarrätten i Göteborg) case number 2276-15, has found a German company to have a permanent establishment (PE) in Sweden due to its annually recurring short-term activities in

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Saudi Arabia-Circular on rules for determining Zakat and income tax liabilities for listed companies

January 09, 2017

The General Authorities for Zakat and Tax (GAZT) amended the determination procedure for the Zakat and income tax liability of listed companies by circular 6768/16/1438 of 4 December 2016. Prior to this, Saudi listed companies were subject to Zakat

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Taiwan: Finance Minister publishes draft rules on CFC and PEM

December 22, 2016

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

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Cyprus: Parliament amended the tax provisions on foreign permanent establishment

December 11, 2016

The Cyprus Parliament passed on 14 October 2016 amendments to the Cyprus Income Tax Law 118/2002, as amended, relating to foreign Permanent Establishments (PEs). Treatment of foreign PEs before the amendment Prior to amendment, profits from a PE

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Indian subsidiary represented by its managing director constitutes a fixed place PE in India

November 10, 2016

Recently, the Chennai Bench of the Income Tax Appellate Tribunal (the Tribunal) in the case of: Carpi Tech SA v. ADIT (ITA No 1742/Mds/2011), held that the amount received by the taxpayer pursuant to NHPC project was taxable in India since the

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Bulgaria: Ownership identification requirement by non-residents with PE

October 06, 2016

Official Gazette has published a Decree No. 306 on 27th September 2016. The Decree forces non-resident companies along with a permanent establishment (PE) in Bulgaria to reveal the shareholder’s names owning a participation of at least 10% in the

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Denmark: Danish Assessment Board issues ruling on profit allocation to permanent establishment

August 22, 2016

The Danish Assessment Board gave its ruling on 16 August 2016, in the case of SKM2016.353.SR on the correct profit allocation to a permanent establishment (PE) in the form of a construction company. Facts of the case: The taxpayer is a foreign

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Israel: Tax provisions in proposed budget plan for 2017-2018

August 17, 2016

The budget plan proposal for 2017-2018 announces significant changes in accordance with international taxation, and would be appropriate for individuals, multinational corporations operating in Israel and Israeli corporations operating abroad. The

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