India: 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 MoreSingapore: financial sector incentive (FSI) revised
The Monetary Authority of Singapore revised the financial sector incentive (FSI) schemes for improving the financial intermediation and to increase the capabilities of financial services and banking activities in Singapore. Within the framework of
See MoreCanada: Minister announces consultation on changes to the Voluntary Disclosures Program
Although most Canadians pay their tax and expect a responsive and fair tax system, some net high wealth individuals are continuing to find ways to avoid paying the tax they owe, placing an unfair burden on the country. The Canadian Government and
See MoreIreland: Charges on income for corporation tax purposes
On 12 June 2017, the Irish Revenue published updates to the Tax and Duty Manual Part 08-02-01 dealing with charges on income for Corporation Tax purposes. The principal updates are in relation to interest as a charge on income under section 247
See MoreFrance: Implementation of withholding tax postponed for one year
The newly elected Prime Minister of France delayed the implementation of withholding tax further by one year, which means this will now enter into force on 1 January 2019. However, the decision will be confirmed by formal vote of the French
See MoreBrazil: The Federal Government establishes the Special Tax Regularization Program
On 31st May 2017 the Federal Government published Provisional Measure No. 783, which established the Special Tax Regularization Program (PERT). Under the program's rules, taxpayers may settle debts with the Federal Revenue Service and the Attorney
See MoreUS: Interest rates on tax underpayments and overpayments for the third quarter of 2017
The Internal Revenue Service on 9 June 2017 announced that interest rates for tax underpayments and overpayments will remain the same for the calendar quarter beginning July 1, 2017. The rates will be: four percent for overpayments (three percent
See MoreMorocco: Finance Law 2017 gazetted
The Government of Morocco published the Finance Law 2017 on 12th of June 2017 in the official gazette. The law provides an anti-avoidance rule, a tax relief in case of dividends, interest, and rental income for real estate collective investment
See MoreMauritius: Budget for 2017-2018
On 8 June 2017, the Prime Minister and Minister of Finance and Economic Development delivered the Budget speech for 2017-18 to the parliament with little change to economic policy. Key points of the budget are summarised below: Reduced corporate tax
See MoreChina announces tax and VAT incentives
The government of China has announced a range of tax incentives including certain reduced rates to boost the Chinese economy. The tax incentive measures include a reduced taxable income threshold for eligible small enterprises to pay corporate
See MoreIreland: New Tax-Geared Penalties for Non-Submission of Returns
On 12 June 2017, Irish Revenue published the manual Tax-Geared Penalties for Non-Submission of Returns, that provides guidance as to the application of tax-geared penalties under section 1077E TCA 1997 in circumstances where the taxpayer has
See MoreIreland: New tax treatment of certain dividends
On 12 June 2017, Irish Revenue published Tax and Duty Manual Part 02-02-03a that deals with the tax treatment of certain foreign dividends paid out of trading profits, which in accordance with section 21B Taxes Consolidation Act 1997, may be
See MoreTaiwan: Draft amendment to controlled foreign company rules issued
Taiwan’s Ministry of Finance issued Ruling No. 10604557490 on 6 June 2017, providing clarification to the proposed controlled foreign company (CFC) regulations which was issued on 9 November 2016. According to the proposed CFC rules, Taiwanese
See MoreIreland: Surcharge on certain undistributed income of close companies
On 8 June 2017, Irish Revenue published the Tax and Duty Manual Part 13-02-05 which deals with the close company surcharge under section 440 TCA 1997, has been updated. The Manual explains that capital allowances are not deductible against estate
See MoreSouth Africa issues guidance on VAT on non-executive director fees
The South African Revenue Service issued guidance on the value added tax (VAT) treatment of fees paid to non-executive directors. On 10 February 2017, SARS issued binding general ruling (BGR) 41 which confirms that a non-executive director (NED) who
See MoreColombia: Tax reform 2016 amends, new CFC rules
On 5 June 2017, the government of Colombia published Decree 939 of 2017 that removed previous errors of articles 89, 99, 111, 123, 165, 180, 281, 289, 305, 317 and 319 of Law 1819 of 2016. In accordance with Law 1819, there are multiple provisions
See MoreGuatemala: Tax fines and surcharges terminated
Public Finance Ministry of Guatemala published Governmental Agreement No. 82-2017 on 4 May 2017, which terminated tax fines, penalties and surcharges for three months starting from 20 May 2017. According to the agreement tax fines, penalties and
See MoreAustralia signs MLI to prevent tax avoidance
Australia has signed the Multilateral Convention to Implement Tax Treaty Related Measures to Prevent Base Erosion and Profit Shifting ("Multilateral Instrument" or "MLI"). The Minister for Trade, Tourism and Investment, Mr. Steven Ciobo MP, signed
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