UK: Online process for tax appeals
Information posted to the UK government website on 3 August 2017 notes that an online service is now available for appeals which can be made directly to the First-tier Tax Tribunal, such as indirect tax appeals or applications for enquiry closure
See MoreMalawi: Tax authority publishes transfer pricing regulations 2017
On 3 July 2017 the Malawi revenue authority published Gazette Notice No 36 of 2017 regarding Taxation (Transfer Pricing Documentation) Regulations 2017. According to the regulation, taxpayers are required to conform to contemporaneous documentation
See MoreRussia submits draft law on automatic international exchange of tax information including documentation requirements
The Russian Government on 20 July 2017, submitted the draft bill (Bill No. 231414-7) on the automatic international exchange of tax information to the Russian State Duma. The draft bill proposes amendments to the Tax Code, which are necessary for
See MoreHong Kong: Government plans to introduce transfer pricing legislation by the end of 2017
On 31 July 2017, the Hong Kong government released the consultation report on measures to counter base erosion and profit shifting (BEPS) by enterprises. Hong Kong indicated its commitment in June 2016 to implementing the BEPS package put forward by
See MoreIndia introduces CbC reporting requirements
India has included a country-by-country (CbC) reporting requirement in section 286 of the Indian Income-tax Act, 1961, with effect from the financial year 2016-2017. The requirements are principally in line with BEPS Action 13. The first round of
See MoreArgentina: Decree No. 593/2017 on incentives published in Official Gazette
Decree No. 593/2017 regarding capital goods was published on July 28, 2017 in the Official Gazette. The Decree is effective from July 1, 2017. This decree modifies incentives under some articles of both Decree No. 379/2001 and Decree No. 594/2004.
See MoreUruguay: Executive Power formally proposes accountability bill 2016
The Executive Power of Uruguay submitted to Congress for consideration the 2016 Accountability Bill on 20 June 2017. The Bill includes provisions on Internet services and the software industry. The bill would also modify the Free Zones (FZ) law. If
See MoreUK: 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On 4 August 2017, UK HM Revenue and Customs (HMRC) published a second draft guidance for public comments on pending corporate interest restriction rules.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
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