China updates foreign tax credit rules
The State Administration of Taxation of China has published Circular 84 of 28 December 2017 regarding the determination of foreign tax credits. According to foreign tax credit rules, resident companies and permanent establishments of non-resident
See MoreArgentina: AFIP publishes a Resolution to amend rules on capital gains tax of nonresidents
The Argentine Tax Authorities (“AFIP”) published General Resolution No 4190/2018 (“GR 4190”) on January 12, 2018 in the Official Gazette and issued it on January 11, 2018. As a result of the recent tax reform enacted through Law 27,430, a
See MorePhilippines: DoF releases the second package of the tax reform bill
The Philippines Department of Finance (DOF) released the second package of the tax reform on 9 January 2018, as part of the country's broader Comprehensive Tax Reform Program (CTRP). Under the Package Two, the DOF aims to lower the CIT rate from 30%
See MoreUS: IRS issues guidance for computing the “transition tax” on foreign earnings
On 29 December 2017, the Treasury Department and the Internal Revenue Service issued Notice 2018-07, which provides guidance for computing the “transition tax” under recent tax legislation enacted on Dec. 22, 2017. In general, newly-issued
See MoreUS: The Nation’s tax season will begin 29 January 2018
On January 4, 2018, the Internal Revenue Service announced that tax collection will begin on Monday, January 29, 2018, and taxpayers are reminded of certain tax credits that the refunds will not be available until the end of February. The IRS will
See MoreItaly: Approves budget Law for 2018
The Italian Budget Law for 2018 (Law no. 205 of 27 December 2017) published on 29 December 2017 and entered into force on 1 January 2018. Some of its most significant corporate tax measures are summarized below: Dividends: Dividends from
See MoreTaiwan: MoF increases dividends withholding tax rate
Taiwan's Ministry of Finance (MoF) has stated that, the withholding tax rate on dividends paid to nonresidents is increased from 20% to 21%. The withholding tax rate effects from 1st January 2018. Ministry of Finance further said that this standard
See MoreLithuania approves the Budget for 2018
On 5 December 2017, Lithuania has adopted the Budget measures for 2018. The most important changes to the Law on corporate income tax are summarized below: An increase in the maximum credit for the investment project incentive from 50% to 100% of
See MoreWorld Tax Brief: December 2017
Australia Sanctions for tax evasion: On 18 December 2017, the Australian Taxation Office was published a draft law companion guideline (LCG) 2017/D7 on Diverted profits tax (DPT) for public consultation. The draft Guideline addresses Schedule 1
See MoreHong Kong: IRD introduces two tiered profits tax rate
The Inland Revenue (Amendment) (No.7) Bill published on 29 December 2017 proposes to modify Hong Kong’s tax relief for various businesses including reinsurance, captive insurance, aircraft leasing, shipping and corporate treasury centers as these
See MoreCanada: 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
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