US: IRS issues additional guidance for computing the “transition tax” on foreign earnings
On 2 April 2018, the Treasury Department and the Internal Revenue Service published additional guidance (Notice 2018-26) for computing the “transition tax” on the untaxed foreign earnings of foreign subsidiaries of U.S. companies under the Tax
See MoreChile: Tax authority issues Ordinances for describing dual corporate tax regimes
The tax authority has published Ordinance 470 and Ordinance 471 of 5 March 2018. It describes the application of the dual corporate tax regimes introduced as of January 1, 2017. These regimes are the standard attribution regime (AIS regime) and the
See MoreRomania: Raised 2018 VAT registration threshold
Romania has introduced a retrospective rise in its VAT registration threshold for resident businesses. It was increased to €88,500 per annum from €65,000 per annum from 1 January 2018. The European Commission last year authorized Romania to
See MoreIreland: New guidance on dividend withholding tax
On 6 April 2018, Irish Revenue has published E-Brief regarding updated guidance on the dividend withholding tax scheme. Dividend Withholding Tax (DWT) - details of scheme: Revenue Tax and Duty Manual Part 06-08A-01, which deals with the operation
See MoreAustralia: Minimum interest rate for simplified transfer pricing record keeping for 2018
The Australian Taxation Office (ATO) has updated its guidance on simplified transfer pricing record keeping options to include the minimum interest rate for the simplified option for low-level outbound loans for the 2018 income year, which is set at
See MoreOECD: Global Forum Issues Peer Review Reports
On 4 April 2018 the OECD’s Global Forum on Transparency and Exchange of Information for Tax Purposes published peer review reports on nine countries. The reports assess the countries’ compliance with the agreed international standards in
See MoreIndia: High Court Decision on separate business segments for benchmarking purposes
On 7 November 2017, the High Court(HC) in the case of: (CIT v. ESPN Software India Limited ) decided that two closely related separate business segments can be combined for arm's length price determination. In this case, the question was whether
See MoreBelgium issues Circular for the settlement of disputes under tax treaties
On 7 March 2018, following the recommendations that were made in Belgium’s BEPS Action 14 (Making Dispute Resolution Mechanisms More Effective) peer review report, the Belgian tax authorities have issued Circular Letter 2018/C/27 on the existing
See MoreAustralia introduces Treasury Laws Amendment (OECD MLI) Bill 2018
On 28 March 2018, the Australian Government introduced Treasury Laws Amendment (OECD Multilateral Instrument) Bill 2018 (the MLI Bill) into Parliament, together with a detailed explanatory memorandum. The MLI bill will need to be passed by the House
See MoreTransfer Pricing Brief: March 2018
Hong Kong: CbC reporting requirement: On 5 March 2018, Hong Kong government announced that it has launched its country-by-country reporting portal. Hong Kong Ultimate Parent Entities of Reportable Groups (HK UPEs) can now file CbC Returns for
See MoreWorld Tax Brief: March 2018
Namibia Main corporate tax rate: On 7 March 2018, the Finance Minister presented the Budget for 2018/19 to the parliament. Accordingly, from 2019, the tax rate for betting and gaming entities may increase to 37% from current 32%. Tax Base: On 7
See MoreSlovak Republic: New PE Rules publishes for digital platforms
The Financial Administration has published a news regarding new permanent establishment (PE) rules for digital platforms. It was introduced by the Tax Reform Law for 2018. In accordance with new PE rules, the registration of the permanent
See MoreEl Salvador: Ministry of Finance publishes updated transfer pricing guidelines
On 21 March 2018, the Ministry of Finance has published the updated transfer pricing guidelines (DG-001/201). The guidelines outline the comparability analysis adjustments and adjustment information provided in the transfer pricing
See MoreJapan: Parliament legislates tax reform plan for 2018
On 28 March 2018, The Diet (Japan’s parliament), enacted the tax reform plan for 2018. The tax law enforcement orders, which are regulations provided by the Government to supplement tax law, were also published in the Official Gazette on 31 March
See MoreChina: Draft Law on Resource Tax
First introduced in 1984, the Resource Tax originally applied to crude oil, natural gas, coal, and other mineral resources based on their quantity and weight. The Chinese Government first extended the Resource Tax nationwide in November 2011. By
See MoreSouth Africa: SARS extends CFCs reporting rules to June
Recently, the South African Revenue Service has declared that it will temporarily allow taxpayers to report information on controlled foreign companies (CFCs) under the old filing rules, which were replaced in February From 1 June 2018 all taxpayers
See MoreHong Kong: IRD gazettes two-tier profits tax rates regime
On 29 March 2018, the Inland Revenue (Amendment) (No. 3) Ordinance 2018 (the Ordinance) was gazetted to implement the two-tiered profits tax rates regime. The two-tiered profits tax rates regime will be applicable to any year of assessment
See MoreThe Swiss Federal Council approves tax proposal 17
The Swiss Federal Council has adopted the dispatch on TP17 for the attention of the Federal Assembly on 21st March 2018. It wishes to quickly to improve matters for domestic and foreign companies with the proposal, also on the basis of international
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