UK: HMRC is seeking comments on pending corporate interest restriction rules
On 4 August 2017, UK HM Revenue and Customs (HMRC) published a second draft guidance for public comments on pending corporate interest restriction rules. An initial tranche of draft guidance was published on 31 March 2017. This second tranche of
See MoreIreland publishes MAP guidelines
On 1 August 2017, Irish Revenue published a guidance on the operation of Mutual Agreement Procedure (MAP) is contained in Tax and Duty Manual Part 35-02-08. The purpose of this guidance is to set out the process through which taxpayers can request
See MoreIreland updates transfer pricing documentation obligations
On 3 August 2017, Irish Revenue published a Tax and Duty Manual Part 35a-01-02 dealing with Transfer Pricing Documentation Obligations. The contents of this manual were previously included in Tax Briefing 07 of
See MoreUK: Timetable for Finance Bill (No. 2) 2017
According to an announcement of 20 July 2017 in Hansard the Ways and Means Resolutions relating to the Finance Bill (No. 2) 2017 are to be submitted to the House of Commons for approval on 6 September 2017. The Bill is expected to be published
See MoreTransfer Pricing Brief: July 2017
Poland: Financial services-Restriction on interest deduction: According to draft bill revising on corporate income tax act published on 12 July 2017, thin capitalization rules limiting the deduction of financing costs to 30% of an adjusted tax
See MoreHungary: Introduced new CFC regime
The amendments to the controlled foreign company (CFC) of Hungary were included in a draft bill which was approved by Parliament on 13 December 2016 and published on 19 December 2016. The new CFC regime is broadly in line with the provisions of the
See MoreWorld Tax Brief: July 2017
Belgium Corporate income tax rate: The federal government of Belgium announced the budget for 2018. The budget has reduced the corporate income tax rate. Currently, the normal rate is 33.99%, will be reduced to 29% in 2018 and in 2019, and will
See MoreIsrael: District Court makes a decision on Israeli transfer pricing rules
A decision was made and governed by an Israeli District Court that when an Israeli company gained IP ownership and shortly thereafter its employees and other assets (with IP) to a related party, the transfer should be counted as a sale for whole
See MoreOECD: Report on small businesses in Canada
On 29 July 2017 the OECD published a report entitled SME and Entrepreneurship Policy in Canada. The report looks at entrepreneurship activity, business structures, federal programmes, productivity and innovation among small and medium enterprises
See MoreGermany publishes revised guidance on CbC reporting requirements
The Germany Federal Ministry of Finance (MoF) on 11 July 2017 issued guidance on the Country-by-Country (CbC) reporting requirements in line with BEPS Action 13 and the EU Administrative Assistance Directive as amended. If certain requirements are
See MoreMexico: Tax authority launches online tax resolution service
The Mexican ax authority has launched an online tax dispute resolution service. The project is a co-operation between the tax authority of the country and the tax administration service which allows people to submit their tax disputes digitally and
See MoreRussia: Proposes a tax incentive for business investments
The Russian government on 19 April 2017, proposed a tax incentive for business investments. Under the proposal, the corporate tax rate would reduce from 20% to 5%. The aim of the incentive is to promote the innovation and modernization of domestic
See MoreBelgium: Tax measures announced for 2018
On 26 July 2017, the federal government of Belgium announced various tax measures for the 2018 budget. Corporate income tax rate The rate of corporate income tax would be gradually reduced. Currently, the normal rate is 33.99%, will be reduced to
See MoreUK: HMRC updates CIRD manual
HMRC’s Corporate Intangibles and Research and Development manual has been updated to reflect a temporary extension to the available period in which to amend a claim to research and expenditure (R&D) tax relief. The extension applies only to
See MoreIMF report looks at US economic prospects and tax reform
On 26 July 2017 the IMF issued a staff report following the conclusion of consultations with the US under Article IV of the IMF’s articles of agreement. The report suggests that in the medium term reforms should include a more efficient tax
See MorePoland: Ministry of Finance publishes a draft bill on corporate income tax
The Polish Ministry of Finance issued a draft bill on 12th July 2017, regarding corporate income tax. The draft bill proposes significant changes and sets new foundations in taxation rules for companies in Poland. The bill changes the
See MoreIceland: Parliament passes legislation amending to interest deduction
The parliament has passed legislation amending article 57(b) of the Income Tax Act No. 90/2003 on 1st June 2017. According to the previous article 57 (b) of the Income Tax Law No 90 /, which entered into force on 1 January 2017, the taxpayer’s
See MoreU.S. and Slovakia sign an agreement on the exchange of CbC reports
According to an IRS announcement on its website, the competent authorities of the U.S. and Slovakia have concluded an arrangement on the exchange of Country-by-Country Reports. The competent authority arrangement (CAA) for exchange of
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