World Tax Brief: August 2018
Austria CFC rule: On 11 July 2018, the Federal Council of Austria adopted the text of the Annual Tax Act 2018 as approved by the National Council (lower house) on 4 July. For the first time, Austria has introduced a comprehensive CFC regime.
See MoreSlovak Republic: President signs a Law to ratify BEPS MLI
The Slovak President, Andrej Kiska, has signed a Law on July 30, 2018, for ratification of the Multilateral Convention to Implement Tax Treaty Related Measures to Prevent BEPS (MLI). This means that Slovak Republic has completed the domestic
See MoreKorea: MOEF proposes tax revision bill for 2018
On 30 July 2018, South Korea's Ministry of Economy and Finance (MOEF) has issued an overview of the proposed 2018 Tax Revision Bill for strengthening social welfare and bringing about redistribution of income, promoting job creation and growth
See MoreRussia modifies the regional corporate tax rate
The Russian Government amended the regional corporation tax rate and published it on 3 August 2018 in the Official Journal. The amendments permit the various regions to repeal the minimum rate of 13.5% in force in their territory from 1 January
See MoreKorea announces tax law amendments proposal for 2019
On 30 July 2018, the Ministry of Strategy and Finance (MOSF) announced its proposed tax law amendments proposal for 2019. This rule will be effective as from tax years beginning on or after 1 January 2020. The summary of the tax amendments proposal
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 MoreTransfer Pricing Brief: August 2018
Australia Rule: On 9 July 2018, ATO published draft Schedule 2 compliance guideline (PCG) 2017/1, covering ATO's compliance approach to transfer pricing issues related to centralized operational models involving procurement, marketing, sales and
See MoreFrance: Court rules transfer pricing re-assessment in determining tax on added value
French tax authorities can consider income that is not “booked” in the accounts of the taxpayer-company for purposes of determining a tax on added value (“Cotisation sur la Valeur Ajoutée”—CVAE) as held by the French Supreme Tax Court
See MoreRomania permits quarterly dividend distributions
On 10 July 2018 the Romanian legislature passed Law no 163/2018 in the Official Gazette allowing quarterly dividend distributions.The Law amended the Accounting Law 1991 and the Companies Law 1990 to provide companies with the option to distribute
See MorePoland releases draft law amending transfer pricing rules
On 16th July 2018, Poland has released a bill to amend the country's transfer pricing rules in line with the results of the BEPS project and the OECD transfer pricing guidelines 2017 in order to improve the taxation of large multinational companies.
See MoreFrance: Tax authority publishes transfer pricing guidelines related to BEPS compliance
On 18 July 2018, the French tax authorities published instructions regarding Master / Local file in the context of transfer pricing documentation. As per the guidelines, the new documentation requirements apply for fiscal years beginning on or
See MoreFrance ratifies MLI to implement tax treaty related measures to prevent BEPS
On 12 July 2018, France ratified the bill by way of Law No. 2018-604, as published in Official Journal No. 0160 of 13 July 2018. On 5 July 2018, the National Assembly passed the bill for the ratification of the multilateral convention to implement
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 MoreSouth Africa: SARS publishes guide on mutual agreement procedures
On 25 July 2018, South African Revenue Service (SARS) released a new guide on the mutual agreement procedure (MAP) that allows competent authorities from the governments of contracting jurisdictions to interact with the intent to resolve
See MoreFrance publishes arm’s length interest rate for third quarter of fiscal year 2018
The arm’s length interest rates used in determining the deductibility of interest payments to shareholders for companies whose fiscal year ends between 30 June 2018 and 29 September 2018 has been published by France. The portion of interest
See MoreEl Salvador: Supreme Court declares various Legislative Decrees regarding tax reforms
The Constitutional Chamber of the Supreme Court of Justice in El Salvador has declared unconstitutional Legislative Decree Nos. 762, 763 and 764 (together, the Legislative Decrees), through which El Salvador reformed its Income Tax Law and Tax Code
See MoreUkraine signs MLI to implement tax treaty related BEPS measures
On 23rd July 2018, Ukrainian Acting Finance Minister Oksana Markarova signed the Multilateral Convention to Implement Tax Treaty Related Measures to Prevent Base Erosion and Profit Shifting. The minister expressed that the signing of the MLI makes
See MoreUS: IRS updates information regarding country-by-country (CbC) reporting
On 25 July 2018, Internal Revenue Service (IRS) updated the information concerning country-by-country (CbC) reporting in the United States. This includes an updated jurisdiction status table showing recently signed competent authority arrangements
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