Chile: 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 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 MoreKorea-Tax Bills for 2017 passed by the National Assembly
The Korean National Assembly passed the Tax Bills for 2017 on 2 December 2016 which was announced by the Ministry of Strategy and Finance (MOSF) on 28 July of 2016. According to the adopted Bill the amount of loss carried forward that a foreign
See MoreCanada: CRA updates a publication about non-Resident tax withholding and remitting
The Canada Revenue Agency (CRA) has updated its publication, T4061 NR4 entitled ‘Non-Resident Tax Withholding, Remitting, and Reporting 2016’ on 6th December 2016. The new publication explains that residents of Estonia have been exempt from tax
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 MoreTaiwan: Debentures and corporate bonds exemption extends
The Legislative permitted the modification of securities transaction taxation, extending the exemption for further 10 years, which means that the securities transaction tax on bank debentures and corporate bonds will be suspended until 31 December
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 MoreFinland: Income received from China on mobile games treated as royalties
The Finnish supreme administrative court issued an order that income on mobile games received by the Finnish company from the Chinese company, under the agreement, constituted royalties in accordance with the treaty. The issue in this case was
See MoreItaly: Resolution publishes regarding interest on medium or long-term loans
The Italian Tax Authorities issued Resolution No. 84/E on 29 September 2016, providing clarifications on the tax treatment of qualifying interest on medium or long-term loans, following the amendments introduced by Law Decree No. 91 of 24 June
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