Hong 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 MoreWorld Tax Brief: August 2019
HungaryIncentive on small business: On 12 July 2019, the Hungarian Lawmakers approved the 2020 budget. The budget reduced the rate of small enterprise tax (KIVA) from 13% to 12% and cancel the simplified entrepreneurial tax (EVA). Payment
See MoreChina: introduces incentives for tourism industry
On 3 August 2019, China's Ministry of Finance and State Taxation Administration have jointly published Notice No. 63 of 2 August 2019 providing incentives to boost up tourism industry in the Guangdong Hengqin New Area. The primary incentive for
See MoreUganda: Parliament passes Income Tax (Amendment) Act 2019
On 30 June 2019, Ugandan Parliament has passed Income Tax Amendment Act 2019. The act contains a number of measures including definition of beneficial owner to reduce the threshold required for exemption; to provide for withholding tax by a seller
See MoreFrance: President signs new Law of digital services tax
The new Law No. 2019-759 has been published on July 25, 2019, in the Official Gazette, which introduces Digital Services Tax (DST). It was signed by the French President, Emmanuel Macron, on July 24, 2019. This new Law also modifies the downward
See MoreTanzania: Government publishes Finance Act, 2019
The Tanzanian Government has published the Finance Act, 2019 in the Official Gazette on 30 June 2019 and it became effective from 1 July 2019. On 13 June 2019, Philip Mpango, the Finance Minister, presented the Budget for financial year (FY)
See MoreColombia: DIAN issues ruling on tax treatment of stock dividends
Recently, the Colombian National Tax Authority (DIAN) published Ruling 014495 of 6 June 2019, which sets out tax of profits in shares or stock dividend. The ruling includes the following points: Article 30 of the Tax Code (TC) provide the
See MoreIndia legislates Finance (No. 2) Act 2019
On 1 August 2019, India has published the Finance (No. 2) Act 2019 in the Official Gazette, which was approved by the president. The measures of the Act are in line with those presented as part of the Union Budget for 2019-20. Corporate tax
See MoreSouth Korea: MOEF proposes tax revision bill for 2019
On 25 July 2019, South Korea’s Ministry of Economy and Finance (MOEF) has issued an overview of the proposed 2019 Tax Revision Bill to raise tax credit rate for corporate facility investments, R&D. The bill mainly focuses on boosting the
See MoreMalta updates NID Guidelines
On 11 July 2019, the Maltese Commissioner for Revenue has issued updated guidelines regarding the Notional Interest Deduction (NID) rules. The updated guidelines explains a number of factors including the determination of the reference rate, the
See MoreGreece: Government announces a wide range of Tax Cuts
Following the recent victory in the countries general election, the new Greek Prime Minister has announced that the government wants to introduce a wide range of tax cuts in order to boost the economy after several years of lack of funding and
See MoreAustralia introduces a bill to amend thin capitalization rules
On 4 July 2019, the Treasury Laws Amendment (Making Sure Multinationals Pay Their Fair Share of Tax in Australia and Other Measures) Bill 2019 was introduced in the Australian House of Representatives. The purpose of the Treasury Laws
See MoreIreland introduces new Guidance on CFC rules
On 22 July 2019, Ireland has published a new Tax and Duty Manual, Part 35b-01-01 in respect of the Controlled Foreign Company (CFC) rules, that were introduced by Finance Act 2018 and take effect from 1 January 2019. The manual provides an
See MoreArgentina: AFIP updates resolution on advance payment of tax
On 12 July 2019, the Federal Administration of Public Revenues (AFIP) of Argentina has published General Resolution No. 4522/2019 amending several provisions of General Resolution 4034 which was issued in 2017. The resolution modifies the
See MoreIndonesia publishes a regulation with tax incentives for investments in certain sectors
On 26 June 2019, the Indonesian government issued a Government Regulation (PP) No. 45 of 2019, which amended Regulation No. 94 of 2010 (GR-94) on the calculation of taxable income and the repayment of income taxes in the current year to stimulate
See MoreUK: Summary of responses to consultation on the restriction on offset of capital losses
On 11 July 2019 the UK government published a summary of responses to the consultation on the restriction of carried forward capital losses, which was held between 29 October 2018 and 25 January 2019. Interested parties submitting responses
See MoreUK: Summary of responses to consultation on digital services tax
On 11 July 2019 the UK government published a document summarising the responses to the consultation on the design of the digital services tax (DST). The DST is to be implemented from April 2020. Certain digital business models derive value
See MoreColombia publishes new thin capitalization rule
On 26 June 2019, the Government of Colombia published a Decree 1146 of 2019, concerning the new thin capitalization rules which amended the previous law 1943 of 2018. The new Decree 1146 of 2019 includes the following measures: The thin
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