Argentina: DJAS and DAPE systems eliminated
The General Resolution No. 4008-E was published on 6th March 2017 in the Argentine Official Gazette. According to that resolution, Argentina has abolished the Early Declaration System for Services (DJAS) and the Early Declaration for Payments Abroad
See MoreUkraine: Amendments to tax code effective from 1 January 2017
The amendments to the Tax Code have been effective, with some exceptions, since 1 January 2017. Below is a summary of the most significant changes in corporate profit tax and transfer pricing. Corporate profit tax: The general tax rate remains
See MoreDTA between Russia and Spain: Russia clarifies taxation of dividends paid to non-resident
The Russian Ministry of Finance (MoF) on 22 February 2017, issued Guidance Letter No. 03-08-05/73316 of 7 December 2016, clarifying the taxation under the Russia - Spain Income and Capital Tax Treaty of the dividends derived by a Spanish
See MoreAngola: Tax provisions released in Budget Law 2017
The budget law 2017 was officially made available to the public on 10th February 2017. The budget law was approved by the National Assembly on 17 November 2017 and was enacted on 31 December 2016. According to Budget Law 2017, the 10% withholding
See MoreSwitzerland: Tax Administration announces safe harbor inter-company interest rates for 2017
The Swiss Federal Tax Administration (SFTA) published safe harbor interest rates on intra-group loans in Swiss Franc as well as in foreign currencies. On 13 February 2017, SFTA released a circular in relation to safe haven interest rates. According
See MoreSouth Africa: SARS issues rulings on employees’ tax and VAT treatment of non-executive directors
The South African Revenue Service (SARS) issued Binding General Ruling (Income Tax) 40 and Binding General Ruling (VAT) 41 on 10 February 2017. Binding General Ruling (Income Tax) 40 clarifies the employees’ tax consequences of income earned by
See MoreTaiwan: National Tax Office clarifies withholding tax on debt-claim income
The National Tax Office of the Central Region issued an announcement on 7 February 2017 regarding withholding tax on interest from short-term commercial papers. According to the announcement, a 10% withholding tax is applies on the gross amount paid
See MoreItaly: Detail corporate tax measures mentioned in Budget Law for 2017
The Italian Budget Law for 2017 entered into force on 1 January 2017. From 2017 financial year, the Italian corporate income tax ("CIT") standard rate is reduced from 27.5% to 24 %. However, Banks, parent companies of banking groups, individual
See MoreIrish Revenue publishes Finance Act 2016
Irish Revenue published Finance Act 2016 that contains multiple additions in relation to Finance Bill 2016, on 12 January 2017. The key changes are following: Directors' fees: An exemption is available on certain emoluments not more than EUR 5,000
See MoreChile: Tax treatment of bonds issued
The Finance Ministry has announced the adjustments declared by Law 20,956 on 30th January 2017 to the tax treatment of bonds that was issued by both the Central Bank and Treasury. Note that, the Central Bank and Treasury are obliged to withhold 4%
See MoreGermany: Government plans to limit the royalty deductions as from 2018
The Federal Ministry of Finance recently approved a draft bill on the limitation of the deduction of royalties on 25 January 2017. The bill focused on foreign IP boxes incompatible with the OECD nexus approach, and to make their use
See MoreMalaysia: Corporate tax proposals under the finance act 2016
The Finance Act 2016, which was gazetted on 16 January 2017, introduces new corporate tax proposals to the Malaysian Income Tax Act (MITA). The highlighted area of the proposals is as given below; Special classes of income are subject to withholding
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 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 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 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 MoreTurkey: General Communiqué No. 11 on CIT Law gazetted
General Communiqué No. 11 regarding the Corporate Income Tax Law (Law No. 5520) was gazetted on 31st December 2016 and amends General Communiqué No. 1. The measure entered into force on the day of its publication. The Communiqué gives
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 More