UK: Changes to non-domiciled rules in Finance Bill (No 2) 2017
Changes to the UK non-domiciled rules that were excluded from the Finance Bill 2017 are to be included in the Finance Bill (No 2) 2017. The Bill is to be published and considered by parliament in September 2017 following the summer recess. Updated
See MoreChina plans to boost up foreign investment
China is striving to become more inviting to FDI and foreign talent by widening market access and improving the business environment. On 28 July 2017, the decision was made at a State Council executive meeting presided over by Premier Li
See MoreRussia: New GAAR provisions in the Tax Code
The Russian parliament on 5 July 2017 approved a draft law (no. 529775-6) introducing a new general anti-avoidance rule (GAAR) into the Tax Code. The new law introduces a new Article 54.1 containing a definition of the limitations on the rights
See MoreRomania: Ordinance on mandatory electronic tax return filing published
Romania has published in the Official Journal of 2 August 2017- Regulation No 2326/2017, according to which tax returns will have to be submitted electronically to the National Agency for Fiscal Administration. Tax returns to be submitted
See MoreNigeria: Government clarifies 27 new industries and products to enjoy tax holiday under pioneer status
The Federal Government gave clarifications on August 9, 2017 regarding businesses that would qualify to enjoy pioneer status under the extra 27 new industries and products for inclusion in the list of “pioneer industries” and “pioneer
See MoreIndia: Tribunal decision on foreign exchange fluctuation gain or loss and arm’s length pricing
The Income-tax Appellate Tribunal in the case of ACIT v. Rajratna Metal Industries Ltd. held that a foreign exchange fluctuation gain/loss is an operating item and is not to be excluded for the purpose of computing the arm’s length price
See MoreUK: Draft guidance on corporate tax loss relief rules
On 31 July 2017 HMRC issued for public consultation draft guidance in relation to the reform to corporate tax loss relief rules. An amended draft of the relevant legislation on corporation tax loss relief was published on 13 July 2017 and this is to
See MoreUK: Updated draft guidance on corporate interest restriction
On 4 August 2017 HMRC issued for public consultation updated draft guidance in relation to the corporate interest restriction rules to be included in the Finance Bill (No 2) 2017. The latest draft guidance amends and updates the initial draft
See MoreSouth Africa: SARS releases draft taxation amendment bill for public comment
The National Treasury and the South African Revenue Service (SARS) published on 19 July 2017 for public comment the 2017 Draft Taxation Laws Amendment Bill (TLAB) and the 2017 Draft Tax Administration Laws Amendment Bill (TALAB). Together with the
See MoreUkraine: SFS clarifies royalty withholding tax received from US
The State Fiscal Service published Guidance Letter No. 722/6/99-99-01-02-02-15/IPK on 19 July 2017 clarifying the royalty withholding tax paid by a US distributor to a Ukrainian software copyright holder. Ukraine's State Fiscal Service ("SFS")
See MoreUK: Online process for tax appeals
Information posted to the UK government website on 3 August 2017 notes that an online service is now available for appeals which can be made directly to the First-tier Tax Tribunal, such as indirect tax appeals or applications for enquiry closure
See MoreMalawi: Tax authority publishes transfer pricing regulations 2017
On 3 July 2017 the Malawi revenue authority published Gazette Notice No 36 of 2017 regarding Taxation (Transfer Pricing Documentation) Regulations 2017. According to the regulation, taxpayers are required to conform to contemporaneous documentation
See MoreRussia submits draft law on automatic international exchange of tax information including documentation requirements
The Russian Government on 20 July 2017, submitted the draft bill (Bill No. 231414-7) on the automatic international exchange of tax information to the Russian State Duma. The draft bill proposes amendments to the Tax Code, which are necessary for
See MoreHong Kong: Government plans to introduce transfer pricing legislation by the end of 2017
On 31 July 2017, the Hong Kong government released the consultation report on measures to counter base erosion and profit shifting (BEPS) by enterprises. Hong Kong indicated its commitment in June 2016 to implementing the BEPS package put forward by
See MoreIndia introduces CbC reporting requirements
India has included a country-by-country (CbC) reporting requirement in section 286 of the Indian Income-tax Act, 1961, with effect from the financial year 2016-2017. The requirements are principally in line with BEPS Action 13. The first round of
See MoreArgentina: Decree No. 593/2017 on incentives published in Official Gazette
Decree No. 593/2017 regarding capital goods was published on July 28, 2017 in the Official Gazette. The Decree is effective from July 1, 2017. This decree modifies incentives under some articles of both Decree No. 379/2001 and Decree No. 594/2004.
See MoreUruguay: Executive Power formally proposes accountability bill 2016
The Executive Power of Uruguay submitted to Congress for consideration the 2016 Accountability Bill on 20 June 2017. The Bill includes provisions on Internet services and the software industry. The bill would also modify the Free Zones (FZ) law. If
See MoreUK: HMRC is seeking comments on pending corporate interest restriction rules
On 4 August 2017, UK HM Revenue and Customs (HMRC) published a second draft guidance for public comments on pending corporate interest restriction rules. An initial tranche of draft guidance was published on 31 March 2017. This second tranche of
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