Canada: Deadline extends for the access of Voluntary Disclosures program
The Canada Revenue Agency (CRA) has extended the deadline for taxpayers to access the current Voluntary Disclosures Program (VDP). In order for a taxpayer to be eligible for the VDP relief outlined in Information Circular IC00-1R5, unintentional
See MoreUkraine: Parliament adopts the amendment to the Tax Code
On 7 December 2017, the Ukrainian Parliament passed the Law of Ukraine "On Amendments to the Tax Code of Ukraine and Certain Laws of Ukraine on Securing Balance of Budget Revenues in 2018” No. 2245-VIII (“Law”). The law came into force on 1
See MoreItaly: Provisions for new patent box regime
Italian Government issued an additional Decree to amend the Italian Patent Box regime in order to streamline the existing differences between the Italian rules and the OECD recommendations set forth under Base Erosion and Profit Shifting (BEPS)
See MoreFrance : Temporary Exceptional Surcharge on Large Companies
The French Constitutional Court finalized the “exceptional surcharges” to levy on corporate income of the French largest companies. This exceptional surcharges apply to French companies or branches that are subject to corporate tax, and have
See MoreUS Tax Cuts and Jobs Act: Global Intangible Low-Taxed Income
The US Tax Cuts and Jobs Act has introduced various new provisions to counter base erosion and profit shifting by US corporations. These include a base erosion minimum tax, provisions to counter income shifting by intangible property transfers and
See MoreUS Tax Cuts and Jobs Act: Income Shifting by Intangible Property Transfers
A U.S. person transferring intangible property to a foreign corporation in a transaction that would otherwise qualify for non-recognition treatment is generally treated as having sold the intangible property in exchange for payments contingent on
See MoreUS Tax Cuts and Jobs Act: Hybrid Transactions and Hybrid Entities
A group could set up an entity that is treated as fiscally transparent for U.S. federal tax purposes but is treated as an entity in the country in which it is resident or subject to tax. Similarly, an instrument may be treated as debt in one country
See MoreUS Tax Cuts and Jobs Act: Base Erosion Minimum Tax
The Tax Cuts and Jobs Act provides for a participation exemption in the form of a 100% deduction for the foreign-source portion of dividends received from 10%-owned foreign corporations. This deduction for dividends received can eliminate additional
See MoreUS: President signs tax cuts and jobs act
On December 22, 2017, President Donald Trump signed the Tax Cuts and Jobs Act (TCJA). On 20 December 2017, both the US Senate and the House of Representatives approved the passing of the Tax Cuts and Jobs Act with some minor changes to comply
See MoreArgentina: Comprehensive tax reform enacts
The Law No. 27430 or comprehensive tax reform was published on December 29, 2017 in the Official Gazette and it generally applies from January 1, 2018. This comprehensive tax reform bill has sent to Congress on December 14, 2017. The Ministry of the
See MoreLuxembourg: Parliament approves the Budget for 2018
On 14 December 2017, the Luxembourg Parliament approved the budget for 2018 and officially published it on 21 December 2017, with the tax measures applicable from 1 January 2018. The corporate tax rate will fall from 19 percent to 18 percent. As a
See MorePoland: President signs the law regarding R&D incentives
The President has signed the Law of 9 November 2017 regarding important amendments to the tax relief regime for research and development on 24th November 2017. It will be effective as of 1 January 2018. This significantly improves the system
See MoreBelgian Parliament enacts corporate tax reform
On 22 December 2017, the Belgian Parliament approved the major corporate tax reform that announced in 26 July 2017. The main proposal was related to gradually reduction of corporate income tax rate. Currently, the normal rate is 33.99% and this will
See MoreRussia publishes clarification regarding the simplified tax system
On 20 November 2017 the Federal Tax Service (FTS) published a clarification regarding the procedure for switching legal entities to a simplified tax system from 2018 onwards. As from 2018, in order to switch to the simplified tax regime, legal
See MoreAustralia: New guidance on DPT
On 18 December 2017, the Australian Taxation Office (ATO) published a draft law companion guideline (LCG) 2017/D7 on Diverted profits tax (DPT) for public consultation. The draft Guideline addresses Schedule 1 to the Treasury Laws Amendment Act 2017
See MoreNetherlands: MoF publishes an overview of tax changes for 2018
The Ministry of Finance (MoF) provides an overview of the most important tax changes as of January 1, 2018, which were approved by parliament on 19th December 2017. It concerns changes in the field of income tax, payroll tax, gift and inheritance
See MoreGreece: Capital gains tax on immovable property suspends for another year
The government on December 20, 2017, announced that it was adding an amendment to a tabled draft justice ministry bill to extend the suspension of the tax measure. Previously, it had been announced that it would take effect in 2018. The current
See MoreChile: Tax authority publishes list of Jurisdictions with preferential tax regime
The Internal Revenue Service (Servicio de Impuestos Internos - SII) of Chile published a Resolution No. 124 of December 19, 2017 regarding list of jurisdictions that are considered to have a preferential tax regime or zero or low taxation. The list
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