Australia: New guidance related to inbound distribution arrangements
On 13 March 2019, the Australian Taxation Office (ATO) released a PCG 2019/1 for all multinational enterprises (MNEs) with distribution operations in Australia. This Guideline outlines compliance approach to the transfer pricing
See MoreUK: Spring Statement 2019
The Chancellor delivered the Spring Statement on 13 March 2019. There were no major tax announcements owing to the uncertainty currently surrounding the UK’s withdrawal from the European Union. UK economic growth is to fall to 1.2% for 2019,
See MoreQatar: New guidance on submitting income tax returns
On 4 March 2019, Qatar's General Tax Authority (GTA) released Circular No. 1/2019 referring to Article 11 of tax law 24 of 2018 and clarifies guidance on submitting income tax returns. The circular informs that taxpayers need to submit their tax
See MorePakistan approves the Finance Supplementary (Second Amendment) Bill, 2019
On 6 March 2019, the National Assembly has approved the Finance Supplementary (Second Amendment) Bill, 2019 aimed at amending tax laws. The major changes introduced to income tax laws are as follow: -For nonbanking sectors, the super tax is
See MoreChina: New rules and requirements for tax compliance
Recently promulgated Chinese tax regulations include following changes affecting corporate income tax: Increase to the unit value of fixed assets eligible for the “one-off deduction method” to RMB 5 million;Increase to the deduction limit
See MoreOECD: Morocco joins the inclusive framework on BEPS
On 9 March 2019 the OECD announced that Morocco has joined the Inclusive Framework on base erosion and profit shifting (BEPS). This means that a total of 129 countries and jurisdictions are taking part in the Inclusive Framework. The countries
See MoreChina aims to reduce taxes in 2019
On 5 March 2019, Mr. Li Keqiang, the Premier declared that the Chinese government is planning to reduce CNT 2 trillion in taxes and fees for companies during 2019. He also included that the government is planning to reduce Value Added Tax (VAT)
See MoreOECD: Consultation on Addressing Tax Challenges of the Digital Economy
On 13 and 14 March 2019 the OECD is to hold a public consultation on the tax challenges of the digitalisation of the economy. This is related to the work on action 1 of the G20/ OECD action plan on base erosion and profit shifting. The consultation
See MoreUS: APMA releases new functional cost diagnostic model (FCD model) for APA submissions
On 26 February 2019, Advance Pricing and Mutual Agreement (APMA) program of IRS, released an excel based functional cost diagnostic model (FCD Model) that is developed in connection with several prior and pending Bilateral Advance Pricing
See MoreTaiwan: NTBNA publishes Guidance on Submission of TP documentation
On 26 February 2019, National Taxation Bureau of the Northern Area (NTBNA), Ministry of Finance of Taiwan has published guidance on the submission of the Master file and Country-by-Country report by MNEs. Here are the key points as follows: The
See MoreIreland updates R&D tax credit
On 6 March 2019, Irish Revenue releasedTax and Duty Manual Part 29-02-03, which includes the Research and Development Tax Credit guidelines. Sections 766, 766A and 766B of the Taxes Consolidation Act (TCA) 1997 (the Act) and the Taxes
See MoreUK: Double tax treaty with Lesotho takes effect
The double tax treaty between the UK and Lesotho takes effect in relation to UK corporation tax for financial years beginning on or after 1 April 2019. The treaty was signed on 3 November 2016 and entered into force on 18 September 2018. Permanent
See MoreTaiwan: NTBND Publishes a clarification on carry forward of losses for exemption from investment income
On 4 March 2019, the National Tax Bureau of the Northern District (NTBND) of the Ministry of Finance of Taiwan issued a clarification on carry-forward of losses for exemption from investment income. Under the clarification following changes
See MoreUK: Tax treaty negotiating priorities for 2019
On 4 March 2019 the UK government set out its tax treaty negotiating priorities for 2019, following discussions with representatives of business, government departments and other interested organisations and individuals. The work program has been
See MoreTransfer Pricing Brief: March 2019
Hong Kong CbC reporting requirement-General rule: On 1 February 2019, Hong Kong Inland Revenue Department (IRD) announced that effective from 1 April 2019, the department will not accept voluntary filing of a CbC return for an accounting period
See MoreWorld Tax Brief: March 2019
Hong Kong Incentives for industry/manufacturing: On 27 February 2019, the Secretary of State presented the 2019/2020 Budget to the Legislative Council. The budget cuts profit tax for 2018/19 by 75%, subject to a ceiling of HKD 20,000, giving
See MoreIreland: Tax relief for new start-up companies
On 1 March 2019, Irish Revenue released Tax and Duty Manual Part 15-03-03 that has been updated to reflect the amendment made in Finance Act 2018 which extended the relief for start-up companies under section 486C of the Taxes
See MoreKenya: Court of Appeal explains the decision about Ruling on income “paid” for Withholding tax
On 5 February 2019, the Kenyan Court of Appeal issued its ruling on: Kenya Revenue Authority v. The Republic of Kenya (ex parte Fintel Limited). In this case, the Court of Appeal overruled the decision of the High Court that the withholding tax
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