Ireland: Irish Revenue publishes guidance on outbound payment measures
On 25 March 2024, the Irish Revenue released eBrief No. 096/24 outlining new guidance on Outbound payments defensive measures. This latest guidance has been issued as part of the Finance (No.2) Act 2023. The Finance (No.2) Act 2023 inserted Chapter
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India: Finance bill 2023 passed in the lower house of Parliament
On 24 March 2023, the lower house of Parliament (Lok Sabha) passed the Finance Bill 2023 which implements tax proposals for the next fiscal year. The Bill received 64 official amendment proposals, among which one intends to remove extended tax
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Belgium introduces new tax rules
On 30 November 2022, new rules on various fiscal and financial provisions were published in the Belgian official Gazette. Starting from 1 January 2023, new rules will enter into force for Belgian companies or Belgian branches. The key tax measures
See MoreGermany issues guidance regarding the obligation to file tax returns for IP
On 14 July 2021, the Federal Ministry of Finance has issued a guidance letter extending the simplified procedure provided in a prior guidance letter dated 11 February 2021 for filing the tax returns in relation to intellectual property
See MoreSouth Korea: National Assembly enacts tax reform bill for 2019
On 31 December 2019, South Korea’s National Assembly has enacted tax reform bill for 2019 with a number of new measures added to the existing proposals including changes in transfer pricing measures. The new and amended tax measures are
See MoreHigh Court rules that the Danish loss-making company could not deduct royalties paid to its Swiss parent
On 28 October 2019, the Eastern High Court of Denmark published a case (Denmark vs Adecco; Case No SKM2019.537.OLR of 4 July 2019) decision and agreed with the tax authority that a Danish loss-making company could not deduct royalties paid to its
See MorePeru: Ministry of Finance publishes Legislative Decree on deductions for royalties and service fees
Peru's Ministry of Finance published Legislative Decree No. 1369 on 2 August 2018 regarding amendments in relation to deductions for royalties and service fees paid to non-residents. The amendment provides that royalties and service fees paid to
See MoreSpain publishes budget act of year 2018
On 4 July 2018, the Spanish Government published Law 6/2018 (the Budget Law 2018) in the Official Journal. The law implementing the fiscal measures from the fiscal year 2018 entered into force on 5 July 2018. Budget contains changes to the patent
See MoreThailand approves an amendment of tax incentive in response to BEPS Action 5
The Thai Cabinet approved an amendment of the tax incentive criteria on 19 June 2018 for the International Headquarters (IHQs) seemingly in response to BEPS Action 5. It limits types of qualified royalty income to only those that are for the result
See MoreMalaysia: IRB issues practice note on tax treatment of digital advertising for non-resident
On 16 March 2018, the Malaysian Inland Revenue Board (IRB) published Practice Note No. 1/2018, which describes the tax implications of income received by a non-Malaysian taxpayer from the provision of digital advertising. The Notice briefly
See MoreIceland: Parliament adopts increased withholding tax rates for 2018
The parliament has approved the Budget for 2018 and it has implemented an overall increase in withholding tax rates effective 1 January 2018 as follows: the standard rate of withholding tax on Icelandic interest, capital gains and dividend income
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 MoreKenya approves Finance Act 2017
The Finance Act 2017, has been gazetted on 23rd June 2017. The Finance Act seeks to amend the law relating to various taxes and duties. Corporate tax related reforms: New motor vehicle assemblers in Kenya will now enjoy a decreased corporate
See MoreUkraine: SFS clarifies royalty withholding tax received from US
The State Fiscal Service published Guidance Letter No. 722/6/99-99-01-02-02-15/IPK on 19 July 2017 clarifying the royalty withholding tax paid by a US distributor to a Ukrainian software copyright holder. Ukraine's State Fiscal Service ("SFS")
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 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
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