Hong Kong: IRD publishes a bill on increasing tax deduction for R & D activities
On 20 April 2018, IRD gazetted the Inland Revenue (Amendment) (No. 3) Bill 2018 to provide for enhanced tax deduction for expenditure incurred by enterprises on qualifying research and development (R&D) activities, in order to encourage more
See MoreSouth Africa: SARS releases a guide to understatement penalties
On 18 April 2018, South African Revenue Service (SARS) published a tax administration guide to understatement penalties under Chapter 16 of the Tax Administration Act 28 of 2011. The guide was first issued on 29 March 2018. The purpose of this guide
See MoreUS: IRS publishes guidance on exhaustion of administrative remedies for foreign tax credit
On 17 April 2018, IRS published a practice unit on Exhaustion of Administrative Remedies in relation to claims for a foreign tax credit. In order for a foreign tax to be creditable under Section 901, it must be compulsory. A payment is compulsory
See MoreUkraine issues a letter on refund of overpayment of income tax by non-resident entity
Recently State Fiscal Service released a personal tax consultation letter regarding the refund of tax incorrectly withheld on income derived from Ukraine sources by a non-resident entity. Generally a 15% standard withholding tax rate is applicable
See MoreZambia: Government publishes new transfer pricing regulations
Zambia published the income tax (transfer pricing) (Amendment) regulations under Statutory Instrument No. 24 of 2018 in the official gazette on 6th April 2018. The 2018 regulations conduct transfer pricing transactions between related entities as
See MoreGreece: Parliament adopts draft bill regarding Multilateral Competent Authority Agreement
The Greek Parliament adopted a draft bill on April 19, 2018, which ratifies the Multilateral Competent Authority Agreement between Greece and United States on the exchange of country by country (CbC) reports. The CbC report is one element of
See MorePuerto Rico: Treasury Department issues Administrative Determination regarding tax returns for 2017
The Puerto Rico Treasury Department has issued Administrative Determination No. 18-07, which determines to grant all taxpayers who file a request for automatic extension to return file for 2017, a total term of 6 months, instead of the term of 3
See MoreDenmark: Eastern High Court applies contemporaneous transfer pricing documentation rule
On 28 March 2018 a summary of a decision of the Eastern High Court in a transfer pricing case involving Microsoft Denmark was published. The case was dealt with by the Supreme Court at first instance after the court had referred it as principle. The
See MoreUK published draft order to bring BEPS MLI into Effect
UK HM Treasury has laid before the House of Commons the draft Double Taxation Relief (Base Erosion and Profit Shifting) Order 2018. After the order is approved, the UK must then deposit its ratification instrument to enter into force in the
See MoreIndia proposes changes in advance ruling forms for transparency in cross-border deals
On 10 April 2018, the central board of direct taxes (CBDT) issued a draft which includes changes to the income tax rules and forms to align them more closely with the OECD’s base erosion and profit shifting (BEPS) Action 5. The draft essentially
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 MoreAustralia: Deadline for R&D Registration
The Research and Development (R&D) Tax Incentive registration deadline for those companies with a 30 June 2017 year end is rapidly approaching. The statutory deadline for lodging an application is 10 months after the end of the income year; for
See MoreColombia issues ruling of CFC exemption
The tax authority of Colombia (DIAN) published a ruling regarding whether the exemption for controlled foreign company (CFC) dividend income paid out of profits from real economic activities will apply if the dividends are paid by a subsidiary of a
See MoreUS: IRS issues guidance on restriction on interest deduction
On 2 April 2018, the Treasury Department and the Internal Revenue Service (IRS) published Notice 2018-28, which provides guidance for computing the business interest expense limitation under recent tax legislation enacted on Dec. 22, 2017. In
See MoreUS: IRS issues guidance on transfer of foreign partnership interests
On 2 April 2018, the Treasury Department and the Internal Revenue Service issued guidance regarding the withholding on the transfer of non-publicly traded partnership interests under the recently enacted Tax Cuts and Jobs Act. In general, the new
See MoreIndonesia launches electronic system for CbC report submission
On 13 April 2018, Directorate General of Taxation of Indonesia has declared the launch of the electronic submission system for Country-by-Country (CbC) reports via the DJP Online Portal. The system provides a step-by-step guideline for the
See MoreUS: IRS offers guidance on ‘blended’ tax rates for corporations under the new tax reform law
On 16 April 2018, the Internal Revenue Service issued a notice that many U.S. corporations elect to use a fiscal year end instead of a calendar year end for federal income tax reporting purposes. Due to a provision in the recently enacted Tax Cuts
See MorePanama issues new form of transfer pricing information return
In accordance with Resolution No. 201-1937 of 2 April 2018, published in the Official Gazette on 9 April 2018, Panama modified Form No. 930 (V1.0), Transfer Pricing Information Return. The new form is Form No. 930
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