Kazakhstan: 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 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 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 MoreCanada: The Federal Budget 2017 announced
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
See MoreIndia: CBDT Publishes draft guidelines for determination of the POEM
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
See MoreSweden: Administrative Court rules PE exists in Sweden due to regular nature of activities
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
See MoreCyprus: Parliament amended the tax provisions on foreign permanent establishment
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
See MoreIndian subsidiary represented by its managing director constitutes a fixed place PE in India
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
See MoreBulgaria: Ownership identification requirement by non-residents with PE
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
See MoreDenmark: Danish Assessment Board issues ruling on profit allocation to permanent establishment
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
See MoreTaiwan : Implements CFC, place of effective management concepts
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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