OECD updates guidance on country by country reporting
On 20 July 2017 the OECD published updates to the guidance on country by country (CbC) reporting requirements under Action 13 of the project on base erosion and profit shifting (BEPS). This guidance for tax administrations and multinational groups
See MoreUK: Impact of video games tax relief
Research has been conducted on behalf of HMRC to look at the impact of video games tax relief (VGTR) on the production of culturally British and European video games. The survey was conducted by holding qualitative in-depth interviews with 51 video
See MoreJapan issues guidance concerning customs valuation opinion
Japan’s customs bureau has recently issued guidance “customs valuation opinion” concerning how retroactive transfer price adjustments are to be addressed from a customs valuation perspective. The customs agency will consider adjustments as
See MoreItaly: Tax ruling on withholding tax exemption for foreign investments in real estate
The Tax Authority of Italy (Agenzia delle Entrate) has issued a tax ruling -Risoluzione n. 78/2017- on 27 June 2017. The ruling is related to certain foreign investment funds which wish to benefit from an exemption from withholding tax. The tax
See MoreCanada and EU: CETA agreement to enter into force
Recently the Prime Minister of Canada and the European Commission announced that they were agreed that the Canada-European Union Comprehensive Economic and Trade Agreement (CETA) would enter into force on September 21, 2017. The CETA will create
See MoreThailand: Consultation process of the draft Transfer Pricing rules
The Revenue Department of Thailand is requesting public comments with respect to the Draft Transfer Pricing Rules which were approved by the Thai Cabinet on May 2015. The comments are to be provided by 7 July 2017. Recently, the draft measures were
See MoreGermany releases guidance on CbC reporting requirements
The Germany Federal Ministry of Finance 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. The guidance clarifies the
See MoreBrazil: Tax authority issues a ruling on tax rates for reinsurers
The tax authority of Brazil has issued COSIT Consultation Response no. 62/2017 (Solução de Consulta n. 62/2017) setting out views of the General Office to Coordinate Taxation (COSIT) on tax rates applicable to reinsurers. The Consultation
See MoreKorea: Recent developments on corporate taxation
With the aim of encouraging the development of new growth-engine industries, reinforcing employment-friendly tax schemes, and facilitating corporate restructuring, a few amendments that affect foreign investment or foreign invested companies have
See MoreIreland: Summer Economic Statement 2017
On 12 July 2017, the Minister for Finance and Public Expenditure & Reform, Mr. Paschal Donohoe T.D, published the Government’s Summer Economic Statement (SES). The Statement is an integral part of the reformed budgetary process that
See MoreEstonia: key changes to corporate income tax rules enacted
The Estonian Minister of Finance submitted the Bill on Amendments to the Income Tax Act (the bill) for consultation on 17 April 2017, which was approved by the Parliament on 19 June 2017. Significant changes in the Income Tax Act include a reduced
See MoreVietnam: National Assembly passes the new technology transfer law
The National Assembly of Vietnam on 19 June 2017 approved the Law on Technology Transfer No. 07/2017 / QH14 ("LTT 2017"). The new law (LTT 2017) comes into force on 1 July 2018 and replaces the Law on Technology Transfer No. 80/2006 / QH11 of 29
See MoreMalaysia: IRBM updates the guidelines for transfer pricing
The Inland Revenue Board of Malaysia (IRBM) had recently announced new updates and changes to the Transfer Pricing Guidelines 2012 (“TPG 2012”). The Malaysian Transfer Pricing Guidelines explain the provision of Section 140A in the Income Tax
See MoreIMF issues report on economic position of Vietnam
On 5 June 2017 the IMF issued a report following the completion of discussions with Vietnam under Article IV of the IMF’s articles of agreement. The report notes that Vietnam’s economy has been performing well with growth of 6.2% in 2016 and
See MoreIMF deputy managing director comments on tax and economic growth in Asia
On 12 July 2017 the IMF Deputy Managing Director Mitsuhiro Furusawa, speaking in Indonesia, commented on the importance of international tax developments for economic growth in Asia. He stressed the importance of revenue mobilization and
See MoreFinland: Tax administration publishes guidance on the allocation of profits to PEs
On 13 June 2017, the Tax Administration published guidance on the allocation of profits to a permanent establishment (PE). A permanent establishment in Finland is liable to Finnish taxation on profits arising in Finland. Permanent establishment
See MoreFrance: Planning to remove CICE Tax Credit
With the aim of creating a more business friendly environment, the French Government is planning to remove the competitiveness and employment (CICE) tax credit and reduce social security contributions. As an approach on this, the CICE tax credit
See MoreUS: IRS releases final versions of CbC form and instructions
The Internal Revenue Service has recently released final versions of the form and instructions for filing country-by-country (CbC) reports. Parent entities of U.S. multinational enterprise (MNE) groups with $850 million or more of revenue in a
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