India: High Court Decision on separate business segments for benchmarking purposes
On 7 November 2017, the High Court(HC) in the case of: (CIT v. ESPN Software India Limited ) decided that two closely related separate business segments can be combined for arm's length price determination. In this case, the question was whether
See MoreBelgium issues Circular for the settlement of disputes under tax treaties
On 7 March 2018, following the recommendations that were made in Belgium’s BEPS Action 14 (Making Dispute Resolution Mechanisms More Effective) peer review report, the Belgian tax authorities have issued Circular Letter 2018/C/27 on the existing
See MoreAustralia introduces Treasury Laws Amendment (OECD MLI) Bill 2018
On 28 March 2018, the Australian Government introduced Treasury Laws Amendment (OECD Multilateral Instrument) Bill 2018 (the MLI Bill) into Parliament, together with a detailed explanatory memorandum. The MLI bill will need to be passed by the House
See MoreTransfer Pricing Brief: March 2018
Hong Kong: CbC reporting requirement: On 5 March 2018, Hong Kong government announced that it has launched its country-by-country reporting portal. Hong Kong Ultimate Parent Entities of Reportable Groups (HK UPEs) can now file CbC Returns for
See MoreWorld Tax Brief: March 2018
Namibia Main corporate tax rate: On 7 March 2018, the Finance Minister presented the Budget for 2018/19 to the parliament. Accordingly, from 2019, the tax rate for betting and gaming entities may increase to 37% from current 32%. Tax Base: On 7
See MoreSlovak Republic: New PE Rules publishes for digital platforms
The Financial Administration has published a news regarding new permanent establishment (PE) rules for digital platforms. It was introduced by the Tax Reform Law for 2018. In accordance with new PE rules, the registration of the permanent
See MoreEl Salvador: Ministry of Finance publishes updated transfer pricing guidelines
On 21 March 2018, the Ministry of Finance has published the updated transfer pricing guidelines (DG-001/201). The guidelines outline the comparability analysis adjustments and adjustment information provided in the transfer pricing
See MoreJapan: Parliament legislates tax reform plan for 2018
On 28 March 2018, The Diet (Japan’s parliament), enacted the tax reform plan for 2018. The tax law enforcement orders, which are regulations provided by the Government to supplement tax law, were also published in the Official Gazette on 31 March
See MoreChina: Draft Law on Resource Tax
First introduced in 1984, the Resource Tax originally applied to crude oil, natural gas, coal, and other mineral resources based on their quantity and weight. The Chinese Government first extended the Resource Tax nationwide in November 2011. By
See MoreSouth Africa: SARS extends CFCs reporting rules to June
Recently, the South African Revenue Service has declared that it will temporarily allow taxpayers to report information on controlled foreign companies (CFCs) under the old filing rules, which were replaced in February From 1 June 2018 all taxpayers
See MoreHong Kong: IRD gazettes two-tier profits tax rates regime
On 29 March 2018, the Inland Revenue (Amendment) (No. 3) Ordinance 2018 (the Ordinance) was gazetted to implement the two-tiered profits tax rates regime. The two-tiered profits tax rates regime will be applicable to any year of assessment
See MoreThe Swiss Federal Council approves tax proposal 17
The Swiss Federal Council has adopted the dispatch on TP17 for the attention of the Federal Assembly on 21st March 2018. It wishes to quickly to improve matters for domestic and foreign companies with the proposal, also on the basis of international
See MoreOECD: Revenue Statistics in Latin America and the Caribbean
On 27 March 2018 the OECD released the latest edition of the publication Revenue Statistics in Latin America and the Caribbean 2018. The publication notes that tax revenues in the region fell in 2016, with an average tax to GDP ratio of 22.7%, 0.3%
See MoreLuxembourg: Government passes new IP tax regime
On 22 March 2018, the bill on the new IP regime was adopted by the Luxembourg Government. The Bill must now be signed into law and published in the Official Gazette to enter into force. Once in force, it is effective from 1 January 2018. The regime
See MorePuerto Rico establishes the procedure for e-filing of the corporate tax return for 2017
The Treasury Department of Puerto Rico has issued guidance (Circular Letter (CL) 18-03) for the electronic filing (e-filing) of corporate income tax returns for tax year 2017. Procedure for electronically file required evidence with the corporation
See MorePoland: Government extends the special economic zone regime
On 20 February 2018, the Polish government adopted the plans to offer tax incentives to investors across the country, not just in areas designated as special economic zones (SEZs). Under the current regime, companies operating with the necessary
See MoreCosta Rica: MOF increases the interest rate for late payments and refunds
On 16 March 2018, the Ministry of Finance (MoF) has increased the interest rate for late payments and refunds of overpayments from 12.8% to 13.73%. The rate is effective from 1 April
See MoreArgentina: Deadline extends for providing incentive benefit
Argentina has published Decree 229/2018 of 16 March 2018 in the Official Gazette. It effects from January 1, 2018. Under Decree 379/2001, this decree changes and extends the effective date for providing incentive up to December 31, 2018. This
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