Australia: Practical Compliance Guideline – cross-border related party financing arrangements and related transactions
On 16 May 2017, the Australian Tax Office (ATO) released a draft Practical Compliance Guideline that sets out the compliance approach for cross-border related party financing arrangements as defined in section 995-1 of the Income Tax Assessment
See MoreNorway: Exemption from withholding tax applies
The tax authorities released a "binding advance ruling" (BFU / 17, 4 May 2017) regarding application of a domestic exemption from dividends to an Irish holding company. The judgment provides that the dividends paid by the Norwegian company to the
See MoreCzech Republic: New withholding tax provisions
The Czech President signed some amendments to the Income Tax Act, which include the withholding tax (WHT) provisions. The amendments will be effective on the 15th day of its publication. There is an indication of its publication date and it is 1st
See MoreUK: Draft legislation – Corporate Interest Restriction
The Corporate Interest Restriction (CIR) legislation was included in Schedule 10 of Finance Bill 2017 but has now been removed. There has been no policy change and the government has announced it will legislate for the provisions at the earliest
See MoreKorea: Country-by-Country reporting requirements and transfer pricing rules updated
The Tax Authority of Korea introduced new forms for country-by-country (CbC) reporting and for the advance notification for recognizing the company of a multinational group as the “reporting entity.” A Master file as well as a Local file will
See MoreSingapore: IRAS launches public consultation on draft GST guide on customer accounting for prescribed goods
The Inland Revenue Authority of Singapore (IRAS) is engaging in a public consultation on the draft Goods and Services Tax (GST) Guide on Customer Accounting for Prescribed Goods. According to the existing GST rules, a GST-registered supplier will
See MoreIndia: Section 14A is subject to dividend income tax regardless of dividend distribution tax (DDT) Payment
Section 14A of the Income Tax Act, 1961 (Act) provides for disallowance of expenditure incurred in relation to income which is not included in the total income of the assessee. The Supreme Court of India in the case of Godrej & Boyce
See MorePakistan: Companies Act 2017 passed by Senate
On 15 May 2017, the Senate approved the draft Companies Bill, 2017, replacing the Companies Ordinance 1984. The Bill aims to facilitate procedures for the country’s business sector and discourage fraud, money laundering and terror
See MoreItaly: Tax guidance clarifying patent box, R&D tax credit, business assets credit issued
The Italian Revenue on 9 March 2017 issued tax guidance, clarifying the Italian patent fund regime, the tax credit for research and development activities (R & D) and the tax credit for new operating assets. According to resolution n. 28/E,
See MoreCroatia publishes the guidance on Advance Pricing Agreements (APAs)
The Minister of Finance, pursuant to Article 14a of the Law on Profit Tax, has issued the ordinance on the procedure for concluding the previous transfer pricing agreement. The ordinance was published in the Official Gazette No. 42/17 on 3 May 2017
See MoreAustralia: Draft Taxation Ruling TR 2017/D2 – Central Management and Control test of residency
The Australian Tax Office has now released a new draft ruling TR 2017/D2 and has withdrawn its preceding ruling TR 2004/15 on the tax residence of foreign incorporated companies. Following the decision in Bywater Investments Limited &
See MoreNew Zealand: Business organization endeavor progressive corporate tax
Small and medium measured organizations (SMEs) in New Zealand need the nation to change partnership charge in accordance with recent changes presented by Australia. It said that 63% of entrepreneurs support presenting a graduated organization tax
See MoreSpain publishes new form for reporting related-party and tax haven transactions
Spain’s Tax Agency has recently published a draft order approving Form 232 for reporting related-party transactions and transactions and situations that involve countries and territories considered to be tax havens. The deadline for filing Form
See MoreFrance: CbC reporting notification and filing obligation
The country reporting (CbC) obligation in France contains a notification according to which French companies subject to the notification obligation are required to mention in their annual corporation tax returns, whether they will be submitting the
See MoreColombia: DIAN clarifies TP filing obligations under BEPS Action 13
On 3 May 2017, the Colombian Tax Authority (DIAN) clarified the fiscal years for which the new transfer pricing obligations established in Article 108 of Law 1819 of 2016 will apply. According to Law 1819, taxpayers have to file a local file, master
See MoreGreece: Parliament adopts a draft bill amending Income Tax Code and VAT Code
The Parliament has adopted a draft bill on 11th of April 2017, which contains some amendments on income tax code and VAT code. The Corporate Income Tax payment needs to be completed by six installments instead of eight. Note that, the first
See MoreItaly: Decree issued on urgent measures on tax matters
The Council of Ministers of Italy enacted a Law Decree No.50 with an effort to meet the European Union (EU) demands of extra budget deficit cuts. The Decree was published in the Official Gazette on 24 April 2017 and provides urgent measures on tax
See MoreCanada: Government offers relief to flood-affected taxpayers
In response to problems caused by the recent flooding across the country, particularly in Quebec and Ontario provinces, the Canadian Revenue Agency (CRA) is making available relief for individuals, businesses, and first responders that are unable to
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