India: Approves amendment in modified special incentive package Scheme
On 18 January 2017, the Indian Union Cabinet has given its approval for amendment in the Modified Special Incentive Package Scheme (M-SIPS) to further incentivize investments in Electronic Sector and moving towards the goal of ‘Net Zero imports’
See MoreUS: IRS issues final and temporary regulation on dividend equivalents from U.S. sources
The IRS on 19 January 2017 issued final and temporary regulations (TD 9815). The final and temporary regulations provides guidance to nonresident alien individuals and foreign corporations that hold certain financial products providing for
See MoreCzech Republic: Bill on automatic exchange of rulings and pricing arrangements approved
A Bill regarding the automatic exchange of advance cross-border rulings and advance pricing arrangements has been approved by the lower chamber of the parliament of Czech Republic on 11th January 2017. It implements the provisions of Council
See MoreGreece: Deadline extension of voluntary disclosure of undeclared income
An amendment to Law 4446/2016 was adopted on 20th January 2017 by the parliament. The amendment made an extension to the deadline for the tax return filing within the framework of the voluntary disclosure of undeclared income. The new deadline is
See MoreBrazil: Tax authority defines withholding tax payments for technical services source in US
Brazilian tax authorities define the withholding tax for technical services made available by individuals in United States through Private Ruling 5/2017 (Solução de Consulta 5/2017), published in the Official Gazette on 18 January 2016. The
See MorePakistan: Introduces an incentive scheme for industrial and trade sectors under no question on source of investment
The government has agreed on a new incentive scheme for industrial and trade sectors under which tax authorities will not question the source of investment, industry sources said on 22 January 2017. Sources in Federal Board of Revenue (FBR) also
See MoreSweden: Administrative Court rules PE exists in Sweden due to regular nature of activities
The Swedish Administrative Court of Appeal in the case of: Gothenburg (Kammarrätten i Göteborg) case number 2276-15, has found a German company to have a permanent establishment (PE) in Sweden due to its annually recurring short-term activities in
See MoreDTA protocol between Brazil and Canada confirm WHT rate on technical services
A Private Ruling 5/2017 (Solução de Consulta 5/2017) has been published in the Official Gazette on 18th January 2016. This ruling confirms that payments made by Brazilian sources to individual or companies resident in Canada for technical
See MoreBelgium: Immovable withholding tax indexation rate of 2017
On 16 January 2017, the Belgian Federal Public Service for Finance issued a circular which discloses the 2017 indexation rate for the immovable withholding tax at 1.7491%. In accordance with the Circular no immovable withholding tax will be due in
See MoreColombia: Tax reform summary 2016
According to law 1819 of 2016, adopting the structural tax reform bill approved on 23 December 2016. It introduces the following major changes to the corporate income tax regime: Income tax rates As from tax year 2019, a single income tax rate of
See MoreDTA between UAE and UK entered into force
The Income Tax Agreement between the United Arab Emirates (UAE) and the United Kingdom (UK) has been come into force on 25th December 2016 for avoiding double taxation and it was signed on 12th April 2016. In accordance with article 26, the
See MoreIndia: Foreign tax credit allowed on the basis of gross receipts
The Ahmedabad Bench of the Income-tax Tribunal (the Tribunal) in the case of Elitecore Technologies Private Limited, held that the Foreign Tax Credit (FTC) is eligible on ‘income’ and not on ‘gross receipts’. However, based on unusual facts
See MoreMalaysia: Finance Act 2017 enacted
The Finance Bill 2016 was enacted as Finance Act 2017 on 16 January 2017. The enacted Finance Act 2017 reduces the corporate tax for the year of assessment 2017 and 2018. The reduced tax rate will be between 1 and 4 percentage points for companies
See MoreMontenegro: Tax debt payment plan announced
The Law on Tax Debt Payment Plan has entered into force and been published in Official Gazette on 31st December 2016. On the basis of the Law, a tax debt may be paid back in 60 monthly installments, if at least 10% of the total debt is repaid in
See MoreSlovenia: Publishes advance pricing agreement rules
Details on the introduction of Advance Pricing Arrangements (APAs) are now available in the Official Gazette on 28 December 2016. Accordingly, the following rules will apply from January 2017: (i) The application of APA must be addressed to the
See MoreColombia introduced dividend tax
According to law 1819 of 2016, Colombia introduced a dividend tax on profits derived as of 1 January 2017, summary as follows: (i) Taxable dividends are subject to 35% final withholding tax and 5% final withholding tax may apply on non-taxable
See MoreGermany: Announces reduction of energy tax for manufacturing companies
The Ministry of Finance issued a press release on 11 January 2017, specifying that be eligible manufacturing companies may apply a percentage of the tax cap on their 2017 electricity and energy tax due because energy consumption reduction goals were
See MoreChile: Announcement on entry into force of new tax regime
The Tax Administration of Chile announced on 5th January 2017 that a new tax regime enters into force from 1st January 2017 as introduced by the 2014 Tax Reform. Companies under the attributed income regime have to pay first category tax at a
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