Colombia 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 MoreArgentina: DTA with Mexico expected to enter into force
The Income Tax Treaty of 2015 between Argentina and Mexico was expected to enter into force on 23 August 2017, after completing the ratification procedure. The provisions of the treaty generally follow the OECD Model Tax Convention. The treaty was
See MorePeru: Amendments to income tax rates
In Peru, Law Decrees Nos. 1258 and 1261 establishing certain amendments to the Income Tax Law were published in the Official Gazette on 8 and 10 December 2016 respectively. According to the amendments the general corporate income tax rate has been
See MoreCanada: Income Tax Folio on capital dividends published
The Canada Revenue Agency (CRA) has published an Income Tax Folio on 15th December 2016 regarding capital dividends (S3-F2-C1). The new Folio is open for comment up to 16th March 2017. Additionally, a general overview of capital dividends and the
See MoreUS: IRS issued on guidance on payment of dividend equivalents from US sources
The Internal Revenue Service on 2 December 2016 issued Notice 2016-76 to provide guidance on compliance in 2017 and 2018 with the final and temporary regulations issued under sections 871(m), 1441, 1461 and 1473 of the US Internal Revenue Code
See MoreFrance-ruling on 75% withholding tax on dividends paid to residents of NCSTs in accordance with constitution
The Constitutional Court of France delivered its decision (No. 2016-598 QPC, Eurofrance) on 25 November 2016 about the compatibility with the constitution of the 75% withholding tax rate applicable to dividends paid to a resident of a
See MoreRussia: MoF clarifications regarding interim dividends
The Finance Ministry (MoF) has issued a letter No. 03-03-06/2/21011 on 13th April 2016 describing the tax treatment of interim dividends paid by a Russian company to its company shareholders in an amount exceeding the net profits of the company in
See MoreRussia: FTS clarifies tax treatment of dividends received by a foreign company
The Federal Tax Service (FTS) has issued a letter no. SD-4-3/2765 on 19th February 2016 for clarifying the tax treatment of dividends received by a foreign company which voluntarily chooses to be considered as a Russian tax resident. According to
See MoreNorway: Fiscal Budget for 2016 Approved with Tax Measures
The Norwegian Government has approved its 2016 Fiscal Budget on 14 December 2015. The corporate income tax rate has been reduced from 27% to 25%. The current limit of NOK15 million increases to NOK20 million for in-house research and development
See MoreFrance: Abolition of add-back on dividends within tax-consolidated groups
An amendment was adopted by the National Assembly on 2 December 2015 to abolish the neutralization within tax consolidated groups of the 5% add-back on dividends qualifying for the participation exemption. The add-back will therefore be reduced to
See MoreRussia: Draft amendments to CFC rules
A draft of Federal Law No. 953192-6 regarding the СFC provisions was submitted to the lower chamber of the parliament on 14th December 2015. The CFC provisions were first provided by the Tax Code and Federal Law No. 376-FZ of 24 November 2014. The
See MoreRussia: MoF clarifies interest expense regarding loans
The Ministry of Finance (MoF) has recently released Letter No. 03-03-06/1/63388 to clarify the applicable tax treatment of interest expense incurred on a loan used to pay dividends. According to Article 252 of the Tax Code (TC) a taxpayer may
See MoreEgypt: Clarification guideline with respect to corporate taxation
The Egyptian Tax Authority published Guideline No. 28 for 2015 on 12 November 2015. The Guideline clarifies certain issues with respect to changes introduced by Decree Law No. 96 for 2015 which amended Income Tax Law No. 91 for 2005. The most
See MoreDenmark publishes a draft bill to relax the taxation of outbound and inbound dividends
The Danish Minister of Taxation published a draft bill on 5 October 2015. This draft bill planned to relax the taxation of certain categories of outbound and inbound dividends in order to comply with European Union (EU) law. However, the proposals
See MoreArgentina-Double Tax Treaty with Switzerland enters into force
The new Double Taxation Treaty between Switzerland and Argentina will enter into force on 27 November 2015. The new treaty will be applicable from 1 January 2015. For taxes withheld at source the relief has become applicable from 2015. The new
See MoreRomania: Proposed reduction of dividend tax from 2016
The Romanian government is planning to cut dividend tax from 2016. At present dividend payments are taxed at 16%. This rate will be reduced to five percent from January 1, 2016, rather than from January 1, 2017 as previously planned. The
See MoreBulgaria: Draft bill to amend tax laws for 2016
The Council of Ministers has approved the bill for amendments to tax laws for 2016 and submitted the draft on 13th October 2015 to the parliament for consideration. The major improvements are as follows: Dividend withholding tax: Implementation of
See MoreThailand: Tax incentives for international headquarters
To promote the location of headquarters in Thailand the Board of Investment has introduced a new program. According to the program there will be relief from corporate income tax (0% on non-Thai source income from services, royalties, and dividends,
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