Sweden:The Administrative Court approves the position of the tax administration on interest on withholding tax refunds
Recently, the Swedish Tax Agency issued a notice concerning a ruling by the Supreme Administrative Court stating that recipients of dividends on which taxes have been levied are entitled to interest if the tax is later refunded. The notice notes
See MoreUK: Statistics on Uptake of Patent Box Relief
From 1 April 2013 the UK phased in Patent Box legislation that allows companies to apply a lower rate of corporation tax to profits earned from patented inventions and other similar forms of intellectual property (IP). The relief was initially
See MoreNetherlands: Budget Proposals 2019
On 18 September 2018, the government of Netherlands presented the 2019 budget proposals to the House of Representatives. Implementation of ATAD measures The Proposals put forward legislation that introduces various EU Anti-Tax Avoidance Directive
See MorePeru: Added new thin Capitalization Rules and Amended Income Tax Law
Peru’s President enacted Legislative Decree 1424 on 13 September 2018, which amends the income tax law with regard to the thin capitalization rules, the indirect transfer of shares, the definition of permanent establishment (PE) and the indirect
See MoreBulgaria: Consultation on draft Law for implementing EU ATAD
The Finance Ministry is consulting on draft legislation for the execution of certain measures of the EU Anti-Tax Avoidance Directive (ATAD). A new interest limitation rule was proposed in this draft Law. This new rule would restrict the amount of
See MoreTurkey: Finance and Treasury Ministry increases interest rates for late payment tax
The Ministry of Finance and Treasury published a Decree No. 62 on September 5, 2018, in the Official Gazette. This Decree contains increase in monthly interest penalty for late payment taxes from 1.4% to 2.0%. Again then on September 6, 2018, a
See MoreSweden: Government announces a legislative proposal to amend the CFC rules
On 4 September 2018, The Swedish government published a legislative proposal to amend the country's controlled foreign company (CFC) rules to comply with the EU Anti-Tax Avoidance Directive (ATAD1). Under the CFC rules, income of foreign entities
See MoreGreece: Prime Minister announces some amendments in tax legislation
The Prime Minister, Alexis Tsipras, announced on September 8, 2018, plans for tax cuts and pledged spending to heal years of painful strictness, less than a month after Greece emerged from a bailout program financed by its European Union partners
See MoreIreland announces corporation tax roadmap
On 5 September 2018, the Minister for Finance and Public Expenditure & Reform, Paschal Donohoe T.D., has published Ireland’s Corporation Tax Roadmap. The Roadmap takes stock of the changing international tax environment, outlines the actions
See MoreUS: Appeal Court Overturns Altera decision on stock based compensation in CSAs
On 24 July 2018 the US Court of Appeals overturned the decision of the Tax Court in the case of Altera Corp, a case that concerned the inclusion of stock based compensation costs in cost sharing agreements (CSAs). The Appeal Court has determined
See MoreWorld Tax Brief: September 2018
Chile Business income taxation: On 21 August 2018, the Chilean president announced that a bill on tax reform would be submitted to Congress. The tax reform laws would propose a single integrated corporate tax system that would eliminate the
See MoreColombia updates late payment interest rate for September 2018
According to an Administrative Regulation 1112 of 2018, the effective monthly interest rate for late payment of taxes has been set at 27.72% and valid from 1 to 30 September
See MoreAustralia: Eligibility changes for the lower corporate tax rate
Changes to the lower corporate tax rate are now law. This means the definition of a base rate entity has changed by replacing the 'carrying on a business' requirement with a passive income test. From the 2017–18 income year, a corporation will be
See MoreChile: 2018 tax reform submits to Congress
The Finance Minister, Felipe Larraín, announced on August 23, 2018, that the draft law for the modernization of taxation was submitted to Congress. It includes modification in the tax system to inspire growth, entrepreneurship, investment, savings,
See MoreFinland: Ministry of Finance issues a draft bill proposing amendments to the CFC rules.
On 6 August 2018, the Finnish MoF published a draft consultation on a draft law that proposed changes to the Finnish CFC rules. The draft law aims to implement the CFC provisions contained in the EU ATAD. The bill would introduce changes to the CFC
See MorePoland: Ministry of Finance declares key changes under 2019 tax reform
Poland’s Ministry of Finance announced, significant changes in the tax law are planned in Poland as of 2019. The Ministry announced the following key measures, among others: Stricter conditions for the application of withholding tax exemption
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 MoreBrazil modifies fines applicable for companies under special regime and exempt entities
Normative Instruction 1,821/2018, published in the Official Gazette of 31 July 2018, modifies the fines applicable to companies taxed under the presumed or determined profit regime and exempt entities as follows: 5% of the gross income in case
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