Colombia: MinHacienda issues decree on taxation of investment funds and PEs
On October 29, the Colombian Ministry of Finance and Public Credit (MinHacienda) has issued Decree 1973, which clarified measures regarding the taxation of private equity funds and collective investment funds and rules on the attribution of income
See MoreMexico: Congress approves tax reform package for 2020
On 30 October 2019, Mexico’s Congress has approved the tax reform for 2020 which was presented by President Andrés Manuel López Obrador’s on September 8, 2019. The Reform incorporates fundamentals of the Base Erosion and Profit Shifting
See MoreUkraine: STS clarifies on determination of profits attributable to PE
The State Tax Service (STS) of Ukraine issued Letter No. 353/ІPK/15-32-05-04-02-15 of 25 September 2019 regarding determination of profits attributable to permanent establishment (PE). Permanent establishment (PE) will be recognized as an
See MoreIndia: ITAT ruled that the Liaison Office of Hitachi constitutes a PE
On 17 September 2019, the Delhi Bench of the Income Tax Appellate Tribunal (ITAT) in the case of: Hitachi High Technologies Singapore Pte Ltd vs. DCIT , held that a Liaison Office (LO) of Hitachi Technologies Singapore Pte Limited constituted a
See MoreNetherlands: Budget proposal for 2020
On 17 September 2019, the Dutch Government published the 2020 budget proposals, which includes the Tax Plan for 2020. The 2020 Tax Plan package consists of the following six bills: the 2020 Tax Plan Bill;the Other 2020 Tax Measures
See MoreDenmark: Draft bill on international taxation submits for public comments
On 12 September 2019, the Ministry of Taxes published a major bill on international taxation. The bill will be subjected to a public hearing and subsequently presented to the Danish Parliament. Interested parties can submit their comments by 10
See MoreMexico: Tax reform proposal in economic package 2020
On 8 September 2019, Mexican president Andrés Manuel López Obrador’s presented Economic Package for the fiscal year 2020 to Congress. The economic package proposed following tax reform measures: Transparent Entities International
See MoreIndonesia: Finance Minister declares tax reform plan
On 3 September 2019, the Minister of Finance, Sri Mulyani Indrawati, announced Government’s tax reform plan through a draft bill. The draft bill proposed following measures: Gradual decrease in corporate rate from 25% to 20% starting from
See MoreHong 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 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 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
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