Kazakhstan: Tax Law Reforms for the year 2018

January 24, 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

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Italy: Approves budget Law for 2018

January 10, 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

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Japan issues tax reform plan for 2018

December 20, 2017

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

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New Zealand: A tax bill to counter tax avoidance introduces into Parliament

December 18, 2017

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

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Italy: Updates definition of permanent establishment

December 17, 2017

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

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Slovak Republic: Government approves draft amendments to Income Tax Act

October 11, 2017

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

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Thailand: New tax, legal requirements for representative offices of foreign companies

September 20, 2017

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

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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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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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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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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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Taiwan : Implements CFC, place of effective management concepts

July 20, 2016

Taiwan’s Legislative Yuan amended the Income Tax Act (ITA) on 12 July 2016, and introduced the controlled foreign company (CFC) rules, incorporating some of the recommendations provided in the Organization for Economic Co-operation and

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