China introduces several incentives for Lingang in Shanghai FTZ
On 6 August 2019,, China announced that it has added the Lingang area to the China (Shanghai) Pilot Free Trade Zone (FTZ) to enhance investment and advance trade liberalization with plans to replicate the concept nationwide, senior officials said.
See MoreFrance: Tax Authority issues a Ruling on interest deduction
The tax authority issued a ruling regarding the deductibility of interest paid to a related Belgian company benefiting from the notional interest regime. On 4 September 2019, the French General Directorate of Public Finance clarified that tax
See MoreWorld Tax Brief: September 2019
TaiwanBusiness income taxation: On 26 August 2019, the Taiwan National Tax Bureau for the Northern Area (NTBNA) published a notice for domestic companies. The Notice clarifies that domestic companies purchasing e-services from a foreign
See MoreTransfer Pricing Brief: September 2019
AustraliaFinancial services: On 28 August 2019, the Australian Taxation Office (ATO) published draft Practical Compliance Guideline PCG 2019/D3, which sets out the proposed compliance approach for the use of the arm’s-length debt test (ALDT)
See MoreCosta Rica: Government announces the budget for 2020
On 30 August 2019, Costa Rican government presented the 2020 budget to the Legislative Assembly which is 4.3% lower than in 2019, thus representing the largest spending reduction in recent years. The tax reform adopted by Congress in December is
See MoreColombia: DIAN issues resolution on MAP
On 13 August 2019, the Colombian National Tax Authority (Dirección de Impuestos y Aduanas Nacionales, DIAN) has published Resolution No. 000053 in the official gazette which establishes Mutual Agreement Procedure (MAP) to avoid double taxation and
See MoreMalaysia releases digital services tax guide
On 20 August 2019, the Royal Malaysian Customs Department published a service tax guide on digital services. The purpose of the guide is to provide a general understanding of the relevant treatment under Sales Tax and Services Tax Legislation and
See MoreUS: IRS publishes interest rates on overpaid and underpaid tax for the 4th quarter of 2019
On 28 August 2019, the Internal Revenue Service announced interest rates on overpaid and underpaid tax for the calendar quarter beginning 1 October 2019 that will remain the same, as they were in the prior quarter. The rates will be 5% for
See MoreLuxembourg implements EU Directive on mandatory disclosure rules
On 8 August 2019, the Luxembourg Government submitted draft law 7465 to the parliament to implement the European Union (EU) mandatory disclosure rules and exchange of information on cross-border tax arrangements (DAC6 or the
See MoreTaiwan: NTBNA issues notice on business tax on e-services purchase
On 26 August 2019, Taiwan's National Taxation Bureau of the Northern Area (NTBNA) has issued a notice for domestic entities to pay business tax on e-services purchased from foreign providers. The notice clarifies about domestic business entity that
See MoreSlovenia implements the mandatory disclosure rules
On 28 May 2019, the Slovenian Parliament has approved the EU Directive on the mandatory disclosure and exchange of cross-border tax arrangements (DAC6). The final Slovenian Mandatory Disclosure Rules legislation is significantly aligned to the
See MorePoland: Ministry of Finance publishes a draft bill to implement EU ATAD 2 anti-hybrid measures
On 23 August 2019, the Poland Ministry of Finance released a draft bill outlining several provisions to implement EU ATAD 2 anti-hybrid measures. The main purpose of implementing the anti-hybrid measures is to counteract the situation of double
See MoreUS: Court of Appeals approves Tax Court’s decision in Transfer Pricing case
On 16 August 2019, the U.S. Court of Appeals for the Ninth Circuit in the case of: Amazon.com, Inc. v. Commissioner, 148 T.C. 108 (2017) issued a decision in favor of Amazon concerning the regulatory definition of intangible assets and the
See MoreCosta Rica publishes resolutions on returns related to capital income, capital gains and others
On 30 July 2019, Costa Rican tax administration released a resolutions amending withholding tax forms and procedures on interest, dividends, and foreign income for the tax period July 2019 forward. The resolution provides several measures
See MoreAustralia: ATO compliance approach to the arm’s length debt test
On 28 August 2019, the Australian Taxation Office (ATO) published draft Practical Compliance Guideline PCG 2019/D3, which sets out the proposed compliance approach for the use of the arm’s-length debt test (ALDT) for the purposes of
See MoreSingapore REIT eligible for WHT exemption in Italy
On 26 August 2019, the Italian tax authority has published Ruling No. 345 regarding the eligibility of a real estate investment trust (REIT) established in Singapore for the withholding tax (WHT) exemption on income derived through a
See MoreNorway launches a consultation proposal on changes to the group contribution rules
On 13 August 2019, the Ministry of Finance published a proposal to amend the group contribution rules regarding EFTA Court rule of 13th September 2017, which found that Norway's rule violated freedom of establishment rights in cases where there is
See MoreFinland: Ministry of Finance announces the budget proposal for 2020
On 16 August 2019, the Finnish Ministry of Finance announced the proposal for the 2020 budget package. The proposal includes following tax measures: A gradual increase tobacco tax by EUR 200 million over the period 2020 to 2023An increase in
See More