Peru: SUNAT simplifies the scope of the CFC rules
On 19 March 2019, the Peru tax authority (SUNAT) issued a guidance (No. 011-2019-SUNAT/7T0000) regarding the determination of expenses and loss offsetting under the controlled foreign company (CFC) rules. The guidance clarified that:
See MoreAustralia: Federal Budget 2019-20
On 2 April 2019, the Australian Government announced its 2019-20 Budget. The Government is lowering taxes for working Australians and backing small and medium‑size business, while ensuring all taxpayers, including big business and multinationals,
See MoreThailand repeals tax incentives under ROH, IHQ and ITC regime
On 26 March 2019, the Thai Cabinet approved three Royal Decrees cancelling all tax incentives provided under the Regional operating headquarters (2010) regime (ROH), International headquarters regime (including Treasury Centres) (IHQ),
See MoreIndonesia: MoF amends the rules for corporate tax holiday
The Minister of Finance (MoF) of Indonesia published a revised tax holiday policy through Regulation No.150/PMK.010/2018 (PMK-150). PMK-150 rules that are nurturing investment in Indonesia, the new regulation reduces the minimum investment
See MoreChina approves new foreign investment law
On 15 March 2019, the National People’s Congress of China has approved the Foreign Investment Law. According to the Foreign Investment Law Chinese subsidiaries of foreign parents will be treated in the same manner as Chinese-owned
See MoreRussia presents a draft bill for the income tax return for small taxpayers
On 21 March 2019, the Russian government announced a bill to amend the income tax return for small taxpayers. The bill requires legal entities with at least 10 employees to file an electronic income tax return and proof of paid insurance from 1
See MoreJapan: Parliament enacts tax reform plans for 2019
On 27 March 2019, Japan's parliament approved the legislation for the government's tax reform proposals for 2019. Some of the main measures are following: Tax incentive: As from 1 April 2019, the tax credit rates will be revised to enhance
See MoreArgentina introduces installment payment option for tax assessment cases before the tax court
On 01 March 2019, the Federal Administration of Public Revenues (AFIP) has published General Resolution 4434 in the official gazette introducing an installment payment facility for tax liabilities in relation to tax assessments that are under
See MoreQatar: GTA issues circular on new income tax law
In April 2019, Qatar's General Tax Authority (GTA) has issued Circular No. 14 of 2019 following previous Law No. 24 of 2018 (the new tax law). The circular provides guidelines to the taxpayers on certain transitional provisions for implementing the
See MoreAlgeria: DGI releases circular on interest deduction regarding finance bill 2019
On 20 March 2019, Algerian tax agency Direction Generale des Impots (DGI) published circular N°1 /MF/DGI/DLRF/LF amending the provision of article 141 of the code of direct taxes and assimilated taxes. The objective of the circular is to explain
See MoreSri Lanka proposes Budget for 2019
On 5 March 2019 Sri Lanka’s Government proposed its National Budget 2019 to the Parliament. The Budget includes following tax measures: -Income tax exemption for interest income accrued to a resident on sovereign bonds in foreign currency, as
See MoreVenezuela extends deadline to file income tax return
On 26 March 2019, Venezuela’s Tax Administration declared the extension date to file income tax return for the fiscal year 2018 because of national power outages. The new date for filling annual income tax return is 30 April
See MoreGreece: Tax administration issues circulars on CIT and Dividend tax rate cut
On 21 March 2019, the Public Revenue Authority issued two circulars (E.2046 / 2019 and E.2047 / 2019) for reducing corporate tax rates and dividend tax rates. These circulars are summarized below: Circular E.2046: This circular confirms that
See MoreCzech Republic published law including CFC rules
On 27 March 2019, the Czech Republic released the Law of 12 March 2019, which includes CFC rules among other changes. A foreign company or permanent establishment will be considered controlled foreign company (CFC) for tax purpose if the Czech
See MoreArgentina publishes tax incentive scheme for local production of certain capital goods
27 March 2019 On 15 March 2019, Argentina published Decree 196/2019 in the official gazette amending Decree No. 379 which was issued in 2001. The decree amends and extends one year (from January 1 to December 31, 2019) tax incentives for the
See MoreQatar: New financial penalties for late submission of tax returns
On 4 March 2019, Qatar's General Tax Authority (GTA) issued Circular No. 1/2019 referring to Article 11 of tax law 24 of 2018 providing guidance to the taxpayers on income tax return submission process as well as the law introducing new financial
See MoreSouth Africa: SARS issues tax interpretation note on lease premiums
On 7 February 2019, South African Revenue Service (SARS) has issued Interpretation Note 109, which clarifies the rules on the tax treatment of lease premiums. The Note explains that, in the earlier year of assessment of receipt or accrual, lessor
See MoreIndia: ITAT ruled that the income which is deemed to accrue or arise in India must have a territorial nexus
Recently, the Mumbai Bench of the Income-tax Appellate Tribunal (ITAT) in the case of: Fox International Channel Asia Pacific Ltd v. DCIT (ITA No.1947/Mum/2015) regarding the taxability of agency commission relating to the services rendered outside
See More