Puerto Rico: Treasury Department issues Administrative Determination regarding tax returns for 2017
The Puerto Rico Treasury Department has issued Administrative Determination No. 18-07, which determines to grant all taxpayers who file a request for automatic extension to return file for 2017, a total term of 6 months, instead of the term of 3
See MoreDenmark: Eastern High Court applies contemporaneous transfer pricing documentation rule
On 28 March 2018 a summary of a decision of the Eastern High Court in a transfer pricing case involving Microsoft Denmark was published. The case was dealt with by the Supreme Court at first instance after the court had referred it as principle. The
See MoreUK published draft order to bring BEPS MLI into Effect
UK HM Treasury has laid before the House of Commons the draft Double Taxation Relief (Base Erosion and Profit Shifting) Order 2018. After the order is approved, the UK must then deposit its ratification instrument to enter into force in the
See MoreIndia proposes changes in advance ruling forms for transparency in cross-border deals
On 10 April 2018, the central board of direct taxes (CBDT) issued a draft which includes changes to the income tax rules and forms to align them more closely with the OECD’s base erosion and profit shifting (BEPS) Action 5. The draft essentially
See MoreMalaysia: IRB issues practice note on tax treatment of digital advertising for non-resident
On 16 March 2018, the Malaysian Inland Revenue Board (IRB) published Practice Note No. 1/2018, which describes the tax implications of income received by a non-Malaysian taxpayer from the provision of digital advertising. The Notice briefly
See MoreAustralia: Deadline for R&D Registration
The Research and Development (R&D) Tax Incentive registration deadline for those companies with a 30 June 2017 year end is rapidly approaching. The statutory deadline for lodging an application is 10 months after the end of the income year; for
See MoreColombia issues ruling of CFC exemption
The tax authority of Colombia (DIAN) published a ruling regarding whether the exemption for controlled foreign company (CFC) dividend income paid out of profits from real economic activities will apply if the dividends are paid by a subsidiary of a
See MoreUS: IRS issues guidance on restriction on interest deduction
On 2 April 2018, the Treasury Department and the Internal Revenue Service (IRS) published Notice 2018-28, which provides guidance for computing the business interest expense limitation under recent tax legislation enacted on Dec. 22, 2017. In
See MoreUS: IRS issues guidance on transfer of foreign partnership interests
On 2 April 2018, the Treasury Department and the Internal Revenue Service issued guidance regarding the withholding on the transfer of non-publicly traded partnership interests under the recently enacted Tax Cuts and Jobs Act. In general, the new
See MoreIndonesia launches electronic system for CbC report submission
On 13 April 2018, Directorate General of Taxation of Indonesia has declared the launch of the electronic submission system for Country-by-Country (CbC) reports via the DJP Online Portal. The system provides a step-by-step guideline for the
See MoreUS: IRS offers guidance on ‘blended’ tax rates for corporations under the new tax reform law
On 16 April 2018, the Internal Revenue Service issued a notice that many U.S. corporations elect to use a fiscal year end instead of a calendar year end for federal income tax reporting purposes. Due to a provision in the recently enacted Tax Cuts
See MorePanama issues new form of transfer pricing information return
In accordance with Resolution No. 201-1937 of 2 April 2018, published in the Official Gazette on 9 April 2018, Panama modified Form No. 930 (V1.0), Transfer Pricing Information Return. The new form is Form No. 930
See MoreSaudi Arabia: Ministerial Resolution amends important articles of the Tax By-law
The Ministerial Resolution No. 1727 provides amendments to Articles 1, 5, 7, 8, 9 and 58 of the Tax By-law. General provisions: The amendment says that shares owned by non-Saudis for speculation purpose in capital companies listed on the KSA stock
See MoreArgentina: Decree 279/2018 was published in the official gazette
The Decree 279/2018 was published on April 9, 2018 in the Official Gazette. The provisions of this decree effects from April 10, 2018. This Decree regulates the scope of the Income Tax of the financial income in order to achieve a correct
See MoreChina announces incentives for integrated circuit production companies
China's Ministry of Finance and Ministry of Industry and Information Technology have issued a notice introducing new tax incentives for qualified integrated circuit (IC) production enterprises. For new IC production enterprises or projects
See MoreTaiwan: Government clarifies transfer pricing documentation thresholds
On 1st April 2018, the Taiwanese government defined how companies should calculate transfer pricing disclosure and documentation thresholds when they operate less than a full year due to fiscal year change, merger, or acquisition. According to the
See MoreCanada: CRA issues MAP program report
The Canada Revenue Agency (CRA) issued the latest mutual agreement procedure (MAP) program report on April 13, 2018. The MAP program is a service provided by the CRA to assist taxpayers in resolving cases of double taxation or taxation not in
See MoreAustria: MOF publishes a draft bill for 2018
On 9 April 2018, the Ministry of Finance (MOF) provided a draft bill for an Annual Tax Act 2018 and submitted it for final consideration. With this draft, the EU Anti-Tax Avoidance Directive (ATAD) will be implemented in Austrian domestic law and in
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