Norway: Finance Minister presents National Budget 2019
The Minister of Finance, Siv Jensen, presented the draft National Budget 2019 on October 8, 2018 to the Parliament. The presentation of the budget will be followed by a cycle of parliamentary hearings and debates on the budget, which will last until
See MoreColombia: Radical Change party submits a tax reform bill to Congress
The Radical Change party, a political party of Colombia submitted a tax reform bill to Congress. The bill contains following proposals: Tax residence The bill would eliminate the requirement to base a company’s tax residence on the company’s
See MoreIndia: CBDT publishes notification for taxation of foreign company held as resident in India as per POEM
On 22 June 2018, the Central Board of Direct Taxes (CBDT) has issued a final Notification No. 29/2018, dealing with special transitional provisions for a foreign company said to be a resident in India on account of Place of Effective Management
See MoreNorway: Government publishes tax proposal in Budget 2018
On 12 October 2017, the Norwegian Government published its proposal for the 2018 Fiscal Budget. The following tax measures are proposed in the Budget. The government has proposed to reduce the general corporate tax rate from 24% to 23% with
See MoreIndia: Clarification guidelines for establishing place of effective management
The Central Board of Direct Taxes recently issued a circular (No. 25 of 2017) on 23 October 2017. This circular clarifies that, as long as the regional headquarter operates for subsidiaries/group companies in a region, within the general and
See MoreZambia: Budget for 2018
Finance Minister of Zambia presented the 2018 National Budget for the year 1 January 2018 to 31 December 2018 to the National Assembly on 29th September 2017. Budget for 2018, which lays out the various expenditure and revenue measures aimed at
See MoreGuernsey: The Beneficial Ownership of Legal Persons Law enacted
The Beneficial Ownership of Legal Persons (Guernsey) Law, 2017 came into force on 15 August 2017. The Law establishes the Office of the Registrar of Beneficial Ownership of Legal Persons, sets out the powers and functions of the Registrar, and
See MoreIndia: CBDT publishes a draft notice on special transitional provisions for a foreign company based in India
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
See MoreAustralia: Draft Taxation Ruling TR 2017/D2 – Central Management and Control test of residency
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 &
See MoreNorway proposes new corporate residency rules
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
See MoreIndia: Clarification on determination of POEM provision
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
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 MoreTaiwan: Finance Minister publishes draft rules on CFC and PEM
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
See MoreIsrael: Tax provisions in proposed budget plan for 2017-2018
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
See MoreRomania: Significant changes brought by the New Fiscal Code
The New Fiscal Code entered into force in Romania on 1 January 2016 addressing important changes in tax area. The New Tax Code introduced the definition of place of effective management, which represents the place where strategic decisions for the
See MoreIndia: CBDT issues draft guidelines for determination of a company’s place of effective management
India's Central Board of Direct Taxes (CBDT) has issued draft guiding principles for determining if a company is a resident in India or has its place of effective management in India. The Finance Act 2015 amended the provisions of section 6(3) of
See MoreCyprus – Company incorporated, but not tax resident of Cyprus
Circular 2014/3 of March 2014 gives guidance in respect of the tax return requirements in the situation where a company is incorporated in Cyprus but is not tax resident in the country. According to the Circular companies in this position must be
See MoreNew Zealand: New rules for determining tax residence
In New Zealand the Inland Revenue Department has issued an “interpretation statement” on tax residence. This is an update to previous guidance from 1989. The new statement takes effect from 1 April 2014 and includes residence criteria for
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