Panama aims to introduce advance pricing agreements
Panamanian Tax Authority (DGI) began a consultation to amend Article 762-L of the tax code to introduce advance pricing agreements (APAs) on transfer pricing issues. The DGI has twelve months to issue a decision and the decisions of the DGI are
See MoreCanada: New tax proposal increases uncertainty for SMEs
A new federal tax proposal was announced on 18th of July 2017 by the Finance Minister and it could have a chance of uncertain consequences for small businesses and enterprises (SMEs). The Canadian Federation of Independent Business (CFIB) has
See MoreIndia: CBDT issues final rules for valuation of unquoted shares
The Central Board of Direct Taxes (CBDT) on 12 July 2017 has issued a notification prescribing the method for valuation of unquoted shares for the purposes of Section 56(2)(x) and Section 50CA of the Income-tax Act 1961. The rules will be effective
See MoreHong Kong: Government plans to introduce tax relief for small and medium enterprises
Following a question regarding two tax measures proposed by Chief Executive in her election manifesto, the Secretary for Financial Services and the Treasury has replied on focusing tax relief for small and medium enterprises. In the 2017-18 Budget,
See MoreGreece: Draft Bill on CbC reporting submitted to the Parliament
The draft bill implementing EU Council Directives 2016/881 regarding mandatory automatic exchange of tax related information (EU CbC reporting) was submitted to the Greek parliament on July 21,
See MoreAustralia: CbC reporting local file instructions now available
On 4 July 2017, the Australian Taxation Office (ATO) published CbC reporting local file instructions together with some guidance on the meaning of “at the same time” for the purposes of the administrative solution. It allows reducing disclosures
See MoreJapan: amendments to CFC rules in 2017 tax reform
The 2017 tax reform bills were passed by the 193rd ordinary session of the Japanese National Diet on 27 March 2017. Accordingly, the Japanese regulations on controlled foreign companies (CFC) have been fundamentally revised, taking into account the
See MoreCyprus: Taxpayers must submit a temporary tax return before 31st July
All companies that are Cyprus tax residents and taxed in accordance with the Cyprus Income Tax Laws and Regulations are required to submit a temporary tax return Form T.D.6 by 31 July 2017. Temporary tax for 2017 is payable in two equal
See MoreArgentina: New Regulations ‘General Resolution 4094-E’ enters into force
The Federal Tax Authority (FTA), on July 18, 2017, published the General Resolution 4094-E on the Official Gazette. This Resolution had been introduced into income tax in 2013. The time when the 2013 tax reform abolished the capital gains tax
See MoreGreece: Draft law regarding TP documentation requirements for CbC reporting
The Parliament of Greece introduced a draft Law 4484/2017 on July 20, 2017 that amends to the Corporate Income Tax Law L.4170 / 2013 and 4474/2017. The suggested amendments contain additional transfer pricing documentation requirements corresponding
See MoreIndia: Physical presence in the source state is not necessary to constitute a service PE
A recent decision of the Bengaluru Bench of the Income-tax Appellate Tribunal (Tribunal) in the case of: ABB FZ-LLC v. DCIT [ITA(TP) No. 1103/Bang/2013, assessed the India-UAE (United Arab Emirates) Double Taxation Avoidance Agreement (tax treaty)
See MoreUK: Updates on Finance Bill (No. 2) 2017
On 20 July 2017, the UK government tabled resolutions for the Finance Bill (No. 2) 2017. The government has now published explanatory notes on resolutions, which give a brief description of each of the Finance Bill resolutions. The Finance Bill (No.
See MoreNetherlands: The Dutch government publishes consultation on anti-tax avoidance directive
The State Secretary of Finance provided a letter to Dutch parliament in which he indicated that an internet consultation has been opened for a draft bill on 10th July 2017. The draft bill has been formulating in order to implement the first EU
See MoreCzech Republic: Chamber of Deputies passes legislation to implement CbC reporting
The chamber of deputies approved a legislation that implements a new information exchange duty, i.e. country-by-country (CbC) reporting into Czech legislation. The legislation will be effective when all legislative and processes are done. According
See MoreCyprus: Tax Authority issues guidance on revised transfer pricing framework
On 30 June 2017, the Cyprus Tax Authorities (CTA) published a Circular revising the transfer pricing framework for companies carrying out intra-group financing activities in Cyprus. The Circular defines intra-group financing transactions as all
See MoreItaly: Revised transfer pricing rules
Decree No. 50 published on 24 April 2017 was implemented on 15 June 2017. According to Article 59 of Decree Law No 50/2017, a corresponding downward adjustment leading to a lower taxable income will no longer be subject to a mutual agreement
See MoreUK: HMRC publishes statistics on creative industries tax relief
On 20 July 2017 HMRC published updated statistics on claims for creative industries tax relief. The statistics include data for film tax relief, high end television tax relief, animation tax relief and video games tax relief, children’s television
See MoreOECD: Revenue Statistics in Asian Countries
On 20 July 2017 the OECD published the latest edition of its publication Revenue Statistics in Asian Countries. This covers trends of revenue statistics in Indonesia, Japan, Kazakhstan, Korea (Rep), Malaysia, Philippines and Singapore between 1990
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