Peru: Ministry of Finance publishes Legislative Decree on deductions for royalties and service fees
Peru's Ministry of Finance published Legislative Decree No. 1369 on 2 August 2018 regarding amendments in relation to deductions for royalties and service fees paid to non-residents. The amendment provides that royalties and service fees paid to
See MoreWTO Issues World Trade Statistical Review 2018
On 31 July 2018 the World Trade Organisation (WTO) issued its World Trade Statistical Review 2018. This looks at developments in world trade and analyses trade in goods and services. The review shows that in 2017 there was stronger growth in world
See MoreGhana changes several Tax Acts
On 1 August 2018, The Parliament of Ghana published in the Official Gazette the Income Tax (Amendment) Act 2018, the National Health Insurance (Amendment) Act 2018, the Ghana Education Trust Fund (Amendment) Act 2018, the Value Added Tax (Amendment)
See MoreColombia issues resolution on Local file and master file submission
CbC reporting requirement-Timing: On 30 July 2018, Resolution 40 of 26 July 2018 was published in the Official Journal. Accordingly, if a constituent entity is required to submit a specific transfer pricing form (form 120), the CbCR notification
See MoreVenezuela grants income tax exemption for hydrocarbon production activities
Venezuela has published Decree No. 3.569 of 1 August 2018 on August 2, 2018 in the Official Gazette. This Decree, removed income tax liability and give an exemption from the territorial and extraterritorial income obtained by Petróleos de Venezuela
See MoreCroatia: Parliament publishes incentive regime for R&D projects
The Parliament has published the Law on State Aid for Research and Development Projects on July 18, 2018. This Act provides for the implementation of state aid measures for R&D projects. This Law was entered into force on the eighth day after
See MorePeru: Published Amendments to the Transfer Pricing Provision in the Official Gazette
Peru published the Legislative Decree No. 1369 (the Decree) on 2 August 2018 in the Official Gazette. The degree amends the transfer pricing provision of the Income Tax Law in order to be aligned with the BEPS project. The main amendments to the
See MoreJamaica: TAJ publishes practice note on final version of transfer pricing agreement
Tax Administration Jamaica (TAJ) recently published the final version of a Transfer Pricing Agreement (TPA) Practice Note. The purpose of the Practice Note is to provide taxpayers and tax officials with guidance on transfer pricing agreements in
See MoreAustralia: ATO issues draft schedule concerning cross border related party financing arrangements
On 1 August 2018, the Australian Taxation Office (ATO) issued a draft Schedule 2 to PCG 2017/4 for public consultation. This guidance addresses the ATO’s compliance approach to taxation issues associated with cross border related party
See MoreAustralia: Improving the integrity of the thin capitalization rules
The Australian Government announced that it will implement two changes to improve the integrity of Australia’s thin capitalization rules in the 2018-19 Budget. The changes are: requiring entities to align the value of their assets for thin
See MoreWorld Tax Brief: August 2018
Austria CFC rule: On 11 July 2018, the Federal Council of Austria adopted the text of the Annual Tax Act 2018 as approved by the National Council (lower house) on 4 July. For the first time, Austria has introduced a comprehensive CFC regime.
See MoreSlovak Republic: President signs a Law to ratify BEPS MLI
The Slovak President, Andrej Kiska, has signed a Law on July 30, 2018, for ratification of the Multilateral Convention to Implement Tax Treaty Related Measures to Prevent BEPS (MLI). This means that Slovak Republic has completed the domestic
See MoreKorea: MOEF proposes tax revision bill for 2018
On 30 July 2018, South Korea's Ministry of Economy and Finance (MOEF) has issued an overview of the proposed 2018 Tax Revision Bill for strengthening social welfare and bringing about redistribution of income, promoting job creation and growth
See MoreRussia modifies the regional corporate tax rate
The Russian Government amended the regional corporation tax rate and published it on 3 August 2018 in the Official Journal. The amendments permit the various regions to repeal the minimum rate of 13.5% in force in their territory from 1 January
See MoreKorea announces tax law amendments proposal for 2019
On 30 July 2018, the Ministry of Strategy and Finance (MOSF) announced its proposed tax law amendments proposal for 2019. This rule will be effective as from tax years beginning on or after 1 January 2020. The summary of the tax amendments proposal
See MoreSpain publishes budget act of year 2018
On 4 July 2018, the Spanish Government published Law 6/2018 (the Budget Law 2018) in the Official Journal. The law implementing the fiscal measures from the fiscal year 2018 entered into force on 5 July 2018. Budget contains changes to the patent
See MoreTransfer Pricing Brief: August 2018
Australia Rule: On 9 July 2018, ATO published draft Schedule 2 compliance guideline (PCG) 2017/1, covering ATO's compliance approach to transfer pricing issues related to centralized operational models involving procurement, marketing, sales and
See MoreFrance: Court rules transfer pricing re-assessment in determining tax on added value
French tax authorities can consider income that is not “booked” in the accounts of the taxpayer-company for purposes of determining a tax on added value (“Cotisation sur la Valeur Ajoutée”—CVAE) as held by the French Supreme Tax Court
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