Korea: Imposed limitation on expense deductions relating to hybrid financial instruments
The 2018 Tax Reform introduces a limitation on deductible expenses relating to hybrid mismatch arrangements as a commitment to implement the hybrid mismatch rules recommended by the Organisation for Economic Co-operation and Development’s. The
See MoreKorea: Increased noncompliance penalties on transfer pricing documentation requirement
Korea has increased noncompliance penalties on transfer pricing documentation requirement. Taxpayers who fail to file a Combined Report of International Transactions (CRIT) or file false information are subject to penalties of KRW10 million
See MorePoland extends the deadline for Transfer Pricing documentation
The Ministry of Finance (MoF) released the Regulation of the Minister of Finance of 14 March 2018 regarding the extension of the deadline for taxpayers to comply with certain transfer pricing documentation obligations on 15th March 2018 in the
See MoreColombia: New income tax return form for 2017
The Colombian national tax authority (DIAN) published a new income tax return form 110 for tax year 2017. The tax payers are obliged to file their income tax return electronically using form 110. DIAN has also published a revised informative
See MoreSingapore: New transfer pricing rules
Singapore Inland Revenue Authority published transfer pricing documentation rules and transfer pricing guidelines in February 2018. The major expansions of the transfer pricing rules are as follows: The arm’s length principle is aligned with
See MoreBrazil changes R&D tax incentives
Brazil released the National Congress Act No. 8 of 14 March 2018 in the Official Journal. The Act extends by 60 Days of Provisional Measure No. 810 of 8 December 2017. This act changes the tax incentive for IT companies investing in research and
See MoreKorea: Important changes in tax rules
The Korean Ministry of Strategy and Finance released amendments to the tax law on 13 February 2018. Key changes are following: The withholding tax rate will increase from 17% to 19% on the amount of compensation paid to hiring foreign entities.
See MoreDominican Republic: DGII modifies the income tax returns for legal entities
With effect from 21 September 2017, the Dominican Tax Administration (DGII) has requested all companies and entities, such as trusts, mutual funds and similar entities, to identify their respective ultimate beneficial owners pursuant to Law 155-07
See MoreOECD: Further guidance on attribution of profits to permanent establishments
On 22 March 2018 the OECD issued a report entitled “Additional Guidance on the Attribution of Profits to Permanent Establishments, BEPS Action 7”. This latest guidance follows the issue of a discussion draft on 22 June 2017 containing guidance
See MoreSlovenia deposited its instrument of ratification of the MLI
The OECD announced on 22 March 2018 that the multilateral monvention to implement tax treaty related measures to prevent base erosion and profit shifting (MLI) will first enter into force on 1 July 2018, following Slovenia’s deposit of the fifth
See MoreSweden proposes a draft bill regarding corporate income tax changes
On 21 March 2018, the Ministry for Finance presented a proposal regarding new legislation within the corporate sector. The proposal comprises new rules on re interest deductions, financial leasing and a reduced corporate tax rate. The proposal is
See MoreAustralia: Closing tax consolidation loopholes
On 22 March 2018, the Australian Government’s commitment to ensure multinationals pay the right amount of tax in Australia continued with the passage through Parliament of the Treasury Laws Amendment (Income Tax Consolidation Integrity) Bill
See MoreBritish Colombia Budget Bill 2-2018 receives Royal Assent
The third reading of Budget Measure Implementation Act, 2018 or Bill 2-2018 for British Colombia (B.C.) was passed on March 14, 2018 in the Craig James, Clerk of the House and received Royal Assent on March 15, 2018. This Bill doesn’t contain any
See MoreSouth Africa updates taxation of foreign dividends guidance
On 22 March 2018, the Government of South Africa released an updated version of its draft interpretation note on the taxation of foreign dividends. The ratios applied in section 10B (3) to calculate the partial exemption applicable to foreign
See MoreOECD announces date of entry into force of multilateral instrument
On 22 March 2018 the OECD announced that the Multilateral Convention to Implement Tax Treaty Related Measures to Prevent Base Erosion and Profit Shifting is to enter into force on 1 July 2018. The Convention allows the signatories to quickly and
See MoreIndian APA accepts customs valuation as arm’s length price for transfer pricing
Recently, the Central Board of Direct Taxes (CBDT) has entered into an advance pricing agreement (APA) where the price determined by the Indian Customs authorities was accepted as arm’s length price for import transactions for transfer pricing
See MoreAgreement to Create the African Continental Free Trade Area
On 21 March 2018 leaders of 44 African countries signed an agreement to create the African Continental Free Trade Area (AfCFTA). The agreement if implemented would remove barriers to trade, such as tariffs and import quotas, allowing the free flow
See MoreBelgium introduces CFC rules and 100% participation exemption
The Belgian corporate income tax reform decreasing the corporate income tax rate to 25% by 2020 (29.58% in 2018 and 2019), also amended a number of measures to increase the attractiveness of Belgium as a holding jurisdiction. Specifically, the
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