Danish Government adopts Law on R&D deductions
On 9 June 2018 Denmark adopted Law on R&D Deductions in the Official Gazette. Law No. 722 of 8 June 2018 provides for an increase in the allowed deduction for R&D from the prior 100% to: 101.5% for the 2018 and 2019 tax years; 103% for
See MoreAngola: President approves new tax regime for natural gas
On 18 May 2018, the President approved the Decree No. 7/18 which outlined new legislation for the development of marginal fields, the creation of a regulatory body for fuel products and natural gas rights. For marginal fields, which the law defines
See MoreBrazil: Maximum tax refund reduces for exporting companies
Brazil has published Decree No. 9.393 of 30th May 2018 in the Official Gazette, which amends Decree No. 8,415, of February 27, 2015, which regulates the application of the special regime for the Reintegration of tax values for exporting
See MoreSweden: Parliament approves draft bill regarding corporate income tax changes
On 14 June 2018, the Swedish Parliament approved the bill introducing new tax rules for the business sector. The bill includes following measures: A reduction in the corporate tax rate from 22% to 21.4% in 2019 and 2020, and to 20.6% from 2021;
See MoreKazakhstan signs MCAA
On 12 June 2018, Kazakhstan signed the Multilateral Competent Authority Agreement (MCAA) on the automatic exchange of Country-by-Country (CbC) reports. Kazakhstan has not yet activated the CbC MCAA in accordance with OECD’s
See MoreAustralia updates international dealings schedule for 2018 tax year
The Australian Taxation Office (ATO) has released the 2018 International dealings schedule (IDS) and their instructions for 2018 tax years. The IDS must be lodged by businesses that provide a response at the trigger questions of the relevant
See MoreBrazilian government adopted several measures regarding incentive in certain sectors
Brazil has published Law 13.670 of 30 May 2018, which was enacted to reduce the number of activities of companies that may continue calculating the social security contributions upon gross revenues of services and/or products. The law includes a
See MoreAustralia updates guidance on R&D tax offsets
The Australian Taxation Office (ATO) has published updated guidance concerning the rate of the Research and Development (R&D) tax offset and whether it is refundable under the R&D tax incentive. If aggregated turnover is less than AUD
See MoreIreland: New guidelines on TP compliance
On May 28, Irish Tax and Customs updated Tax and Duty Manual Part 35A-01-01 to set out the government’s approach to monitoring compliance with transfer pricing legislation contained in Part 35A of the Taxes Consolidation Act 1997. The new
See MoreBangladesh: Income Tax Proposal in Fiscal Budget 2018-2019
Finance Minister Mr. AMA Muhith presented the FY2018-19 national budget to parliament on 7th June 2018. Except for a minor downward tweaking of the corporate tax rate, and some small increases in tobacco taxation and supplementary import duties, no
See MoreGermany: The CJEU decision permits deviations from the arm’s length principle
On 31 May 2018, the Court of Justice of the European Union (CJEU) issued its decision in the case of: C-382/16 Hornbach-Baumarkt that a parent company’s position as a shareholder of a non-resident company may be taken into account in
See MoreJapan: Diet passes Bill on the Multilateral Instrument (MLI)
On May 18, 2018, the Japanese legislature passed the Bill on the Multilateral Instrument (MLI). This means that Japan has completed the national process of ratifying the MLI. The next step is for Japan to deposit its instrument of ratification,
See MoreChile: Tax authority publishes a Circular regarding transitional relief
The tax authority (SII) has released Circular No. 31 of 23 May 2018. It assures the transition relief provided regarding dividends paid by taxpayers under the partially integrated regime (PIS). The tax authority has also published Ordinance 470 and
See MoreCanada: Minister tables Notice of Ways and Means Motion to implement BEPS MLI
The Finance Minister, Bill Morneau, tabled a Notice of Ways and Means Motion in the House of Commons on May 28, 2018, for formalizing the Government's intention to introduce legislation that would enact the Multilateral Convention to Implement Tax
See MoreWorld Tax Brief: June 2018
Hong Kong Main corporate tax rate: On 16 May 2018, the Legislative Council passed the Inland Revenue (Amendment) Bill 2018 providing special tax measures including a 75% one-off reduction in profits tax, for the year of assessment 2017/18 is
See MoreArgentina: Government publishes General Resolution 4245/2018
On 16 May 2018, Argentina has published a General Resolution (4245/2018 of 15 May 2018) on their official website. The Resolution 4245 modifies the General Resolution 830/2000, which introduced income tax withholding on particular payments made
See MoreSlovenia publishes the clarification on MAP procedure
The Ministry of Finance of the Republic of Slovenia published the clarification on the Mutual Agreement procedure (MAP) on 7 May 2018, which is set out in the MAP scheme of the Slovenian Tax Treaty Network. The clarification provides detail in the
See MoreTransfer Pricing Brief: June 2018
Sweden: Financial services-Restriction on interest deduction: On 3 May 2018, draft legislation has been submitted to the Swedish parliament which includes safe harbour rule and limit to interest deduction. Under the proposed rules, the
See More