US: IRS issues new advance pricing agreement (APA) template
On May 11, 2018, the IRS’s Advance Pricing and Mutual Agreement Program (APMA) issued a new template that taxpayers must use when requesting an advance pricing agreement (APA) under Rev. Proc. 2015-41, 2015-35 I.R.B. 263 (Rev. Proc. 2015-41).
See MoreCayman Islands: DITC released official guidance on the CbC reporting requirements
The Cayman Islands’ Department for International Tax Cooperation (“DITC”) released their official guidance on March 29, 2018 regarding the Country-by-Country (“CbC”) reporting requirements of entities that are resident in the Cayman
See MorePoland: Parliament enacts draft bill regarding supporting new investments
The lower chamber of the parliament enacted a draft bill regarding Supporting New Investments ( Ustawa o wspieraniu nowych inwestycji ) on 10th May 2018. The draft law will be presented to the higher chamber after some amendments. According to the
See MoreRussia approves format for CbC Reports and Notification for multinational groups
On 6 May 2018, Russia’s Federal Tax Services (FTS) issued Order No. MMV-7-17/123 and Order No. MMV-7-17/124 issued on 26 April 2018 in the Official Gazette. The orders approves the format and method of submission for Country-by-Country (CbC)
See MoreItaly issues final transfer pricing regulations on the application of the arm’s length principle
Italy issued final transfer pricing regulations on May 14 regarding the application of the arm’s length principle. The publication follows the release of a draft for public consultation in February and a consultation in May. The guidance supports
See MoreTaiwan releases tax ruling regarding calculating Taiwan-sourced income of foreign entities
The Ministry of Finance released a tax ruling regarding the new method of calculating income source from Taiwan originating from foreign companies that import, store, manufacture and deliver goods to domestic and foreign customers. According to the
See MoreSouth Africa: SARS issues notice on penalties for non-compliance of CbC report
On 11 May 2018, the South African Revenue Service (SARS) released a notice concerning penalties which provides taxpayer fails to submit returns (CbC report, Master File, Local file) by the deadline will be subject to a fixed penalty up to ZAR 16,000
See MoreSerbia: Parliament adopts law on tax procedure and tax administration
On April 19, 2018, the Serbian parliament passed the Law on Amendments to the Law on Tax Procedures and Tax Administration. The law was published in the Official Gazette of the Republic of Serbia No. 30 of April 20, 2018. The submission of a tax
See MoreSingapore changes to tax reliefs for firms in pioneer industries
On 5 May 2018, Singapore has published the Economic Expansion Incentives (Amendment) Act 2018 and the related Commencement Notification and Regulations in the Official Gazette. The Act and Regulations provide for the exclusion of income from
See MoreSouth Africa: SARS publishes new interest rate table charged on tax compliance
On 7 May 2018, the South African Revenue Service has published an updated rate table for interest charged on outstanding taxes, duties, and levies, and interest rates payable in respect of refunds of tax on successful appeals and certain delayed
See MoreMalaysia: New government plans to reduce GST from 1st June 2018
On May 16, 2018, the new Malaysian government said it will reduce the tax on goods and services to zero from June 1 and effectively abolish it. In a statement from the Ministry of Finance, all registered traders have been instructed to comply
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United Nations Releases Extractive Industries Handbook
The United Nations has released the Extractive Industries Handbook at the 16th Session of the UN Committee of Experts held in New York from 14 to 17 May 2018. The handbook focuses on specific areas on interest for developing countries in taxing
See MoreLithuania: MoF proposes to amend the Corporate Income Tax Law
The Ministry of Finance has published a bill to ease the restrictions on the preferential corporate tax rate (5%) for SMEs. The bill, which was published in the Official Journal on 7 May 2018, and the adoption by Parliament, will enter into force on
See MoreFinland: Tax administration issued guidelines on the allocation of profits to PE
On 30 April 2018, the tax administration published a guideline no.A72/200/2018 on profit distribution for a permanent establishment (PE). The guidelines clarify that, upon request, a foreign company has to specify how it has allocated profits to a
See MoreUS and Indonesia sign MOU on the exchange of CbC reports
On April 26, 2018, the Internal Revenue Service issued a Memorandum of Understanding (MOU) between the Competent Authorities of the United States (US) and Indonesia, which includes an announcement of the temporary suspension of Indonesia's secondary
See MoreAustralia: Federal Budget 2018
On 8 May 2018, the Commonwealth Treasurer, Mr. Scott Morrison, announced the Federal Budget 2018-19. Mr. Morrison said “in this year's Budget there are five things we must do to further strengthen our economy to guarantee the essentials
See MoreSweden: The Draft legislation regarding corporate tax changes submits to the parliament
On 3 May 2018, the draft law was submitted to the Swedish Parliament for the introduction of new tax rules for the corporate sector. The proposal comprises new rules on re interest deductions, financial leasing and a reduced corporate tax rate. The
See MoreRussia publishes bilateral and multilateral APA Procedure
On 3 May 2018, Russia published Decree No. 60 on the Official Gazette, which approves the procedures for the conclusion of advance pricing agreements (APAs). The Russian Finance Ministry delegated the competent authority powers with respect to
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