France: New tax plans by the newly elected president
French newly elected president has committed to reduce the corporate tax rate from current rate of 33.3% to 25% with the aim to bring it in line with the EU average within five years. The tax credit on research, innovation and the start-up status
See MoreNorway: Exemption from withholding tax applies
The tax authorities released a "binding advance ruling" (BFU / 17, 4 May 2017) regarding application of a domestic exemption from dividends to an Irish holding company. The judgment provides that the dividends paid by the Norwegian company to the
See MoreNetherlands releases explanation on dividend withholding tax exemption for exempt companies
The Dutch Tax and Customs Administration has issued an explanation on 30 March 2017 regarding dividend withholding tax exemption for exempt companies. According to the explanation domestic and foreign entities which are exempt from corporate income
See MoreOman: Treatment of withholding tax on dividends
On 20 March 2017, the Capital Market Authority of Oman issued Circular E/3/2017 clarifying the application of withholding tax on dividends recently introduced by way of Royal Decree 9 of 26 February 2017. The circular clarifies that the withholding
See MoreIndia: Payments to Belgian entities not taxable as fees for technical services
Recently, the Ahmedabad Bench of the Income-tax Appellate Tribunal in the case of: ITO v. Cadila Health Care Ltd 78, decided that the payments made to Belgian entities are not taxable as “Fees for Technical Services (FTS)” in view of Most
See MoreArgentina: 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
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