Taiwan: Draft amendment to controlled foreign company rules issued
Taiwan’s Ministry of Finance issued Ruling No. 10604557490 on 6 June 2017, providing clarification to the proposed controlled foreign company (CFC) regulations which was issued on 9 November 2016. According to the proposed CFC rules, Taiwanese
See MoreIreland: Surcharge on certain undistributed income of close companies
On 8 June 2017, Irish Revenue published the Tax and Duty Manual Part 13-02-05 which deals with the close company surcharge under section 440 TCA 1997, has been updated. The Manual explains that capital allowances are not deductible against estate
See MoreSouth Africa issues guidance on VAT on non-executive director fees
The South African Revenue Service issued guidance on the value added tax (VAT) treatment of fees paid to non-executive directors. On 10 February 2017, SARS issued binding general ruling (BGR) 41 which confirms that a non-executive director (NED) who
See MoreIreland: DAC2/CRS return deadline extended
The Irish revenue has delayed the filing deadline for DAC2/CRS returns until 18 August 2017. As the opportunity to begin filing is delayed, revenue reminds customers that the Registration facility for DAC2/CRS is still fully operational and
See MoreColombia: Tax reform 2016 amends, new CFC rules
On 5 June 2017, the government of Colombia published Decree 939 of 2017 that removed previous errors of articles 89, 99, 111, 123, 165, 180, 281, 289, 305, 317 and 319 of Law 1819 of 2016. In accordance with Law 1819, there are multiple provisions
See MoreIndia: CBDT notifies new safe harbour regime for cross-border transactions
The Central Board of Direct Taxes (CBDT) on 7 June 2017, has issued a new, relaxed, safe harbour regime in order to reduce transfer pricing disputes. The move is aimed at providing certainty to taxpayers, aligning safe harbour margins with industry
See MoreTurkey signs CRS Multilateral Competent Authority Agreement
Turkey has signed Common Reporting Multilateral Competent Authority Agreement (CRS MCAA) for the implementation of automatic exchange of financial account information pursuant to the OECD/G20 Common Reporting Standard (CRS) to launch exchanges in
See MoreNetherlands: Bill on country-by-country reporting gazetted
The lower house of the Dutch parliament adopted a bill implementing EU directive 2016/881, mandating the automatic exchange of country-by-country reporting information among EU member states on 26th April 2017. On 2nd June 2017, EU directive
See MorePakistan: FBR proposes to introduce a Directorate General of Transfer pricing
Federal Board of Revenue (FBR) has proposed through Finance Bill 2017 to establish Directorate General of Transfer Pricing which shall consist of a Director General and as many Directors, Additional Directors, Deputy Directors, Assistant Directors
See MoreRomania: Country-by-Country reporting requirement modified
The Romanian Ministry of Finance published a draft law on 24 May 2017 to modify the CbC reporting legislation of the country. According to the draft law, all Romanian tax resident entities which are ultimate parent of an MNE Group with annual
See MoreGuatemala: Tax fines and surcharges terminated
Public Finance Ministry of Guatemala published Governmental Agreement No. 82-2017 on 4 May 2017, which terminated tax fines, penalties and surcharges for three months starting from 20 May 2017. According to the agreement tax fines, penalties and
See MoreAustralia signs MLI to prevent tax avoidance
Australia has signed the Multilateral Convention to Implement Tax Treaty Related Measures to Prevent Base Erosion and Profit Shifting ("Multilateral Instrument" or "MLI"). The Minister for Trade, Tourism and Investment, Mr. Steven Ciobo MP, signed
See MoreIsle of Man signs MLI to prevent tax avoidance
On 7 June 2017, the Treasury Minister of Isle of Man, Mr. Alfred Cannan MHK has signed the Multilateral Convention to Implement Tax Treaty Related Measures to Prevent Base Erosion and Profit Shifting (“Multilateral Instrument” or “MLI”) in
See MoreChina announces tax incentives to boost up tech SMEs
On 3 May 2017, China announced measures to encourage research and development (R&D) by tech firms through favorable tax terms. Small and medium sized-enterprises (SME) in the technological sector can deduct an additional 75% of the R&D costs
See MoreUK signs MLI to prevent tax avoidance
On 7 June 2017, United Kingdom has signed the Multilateral Convention to Implement Tax Treaty Related Measures to Prevent Base Erosion and Profit Shifting (“Multilateral Instrument” or “MLI”) in Paris. Total 68 countries, including
See MoreIreland signs MLI to prevent tax avoidance
On 7 June 2017, Finance Minister Mr. Michael Noonan T.D. has signed the OECD Multilateral Convention to Implement Tax Treaty Related Measures to Prevent Base Erosion and Profit Shifting (“Multilateral Instrument” or “MLI”) on behalf of
See MoreBahamas: Budget Communication 2017-18
The Bahamas 2017-18 Budget was submitted to the National Assembly on May 31, 2017. The budget included an increase in customs and excise duties and licensing taxes and the introduction of electronic customs procedures. The main changes are as
See MoreSpain: Lower House approves 2017 Budget
Spain's lower house on 1 June 2017 approved the delayed 2017 national budget. The budget was presented on April 4th 2017. There is no significant change on direct taxation. A 10% reduced rate of VAT is expected to apply to specific product supplies
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