Mexico: Amendments to tax reform package
The Decree including the tax reform package for 2017 was released in the Official Gazette on 30 November 2016. According to the decree the Legal representatives must acquire a taxpayer registration number and an electronic signature. The instructive
See MoreBolivia: Publishes audit procedure rules
The National Tax Service published Resolution No. 10-0032-16 (the Resolution) on 27 November 2016. The Resolution contains the formalities to be observed by the tax authorities during an audit procedure carried out to verify tax liabilities
See MoreBulgaria: Transfer pricing regulations
Bulgaria fully follows and applies the OECD Transfer Pricing (TP) guidelines and has had robust TP rules for several years, but taxpayers must be concerned about the regulations. The TP rules were first announced in the Corporate Income Tax Act
See MoreFrance-ruling on 75% withholding tax on dividends paid to residents of NCSTs in accordance with constitution
The Constitutional Court of France delivered its decision (No. 2016-598 QPC, Eurofrance) on 25 November 2016 about the compatibility with the constitution of the 75% withholding tax rate applicable to dividends paid to a resident of a
See MoreHong Kong: IRD explains the appeal process against tax assessment
The Inland Revenue Department has published their revised Interpretation and Practice Note No. 6 to reflect legislative changes to the rights of appeal against tax assessments, which began to be applied from April 1 this year. These notes are issued
See MoreAustralian government asking for comment on diverted profits tax legislation
In the 2016-17 Budget, the Australian Government announced that it would implement a Diverted Profits Tax (DPT) to impose a 40% penalty tax on profits that have been artificially diverted from Australia by multinationals. This exposure draft Bill
See MoreZambia: Draft Budget for 2017
The Minister of Finance submitted the 2017 Draft Budget to the National Assembly on 11 November 2016. The proposed measures regarding to direct taxation as enclosed in the Budget are given below- Corporate taxation: The capital payment rate on
See MoreNetherlands: Fourth amending bill presents to lower house of parliament
The fourth amending bill to the Tax Plan 2017 No. 34 522 (No. 37) was released in the Official Gazette on 15 November 2016. It was presented by the Minister of Finance to the lower house of the parliament on 20 September 2016. The major amendment
See MoreGermany: Publishes social security contributions thresholds for 2017
The Federal Council approved the regulation concerning the thresholds for social security contributions for 2017 on 25 November 2016, which had been previously approved by the Federal Cabinet on 12 October
See MoreSpain: New law introducing tax measures addressed to the reduction of the public deficit
Royal Decree-Law 2/2016 released on 30 September 2016 focuses on reducing the public deficit by introducing corporate income tax measures that aim at raising revenue. An increase of the rate applicable to corporate income tax “prepayments” tax
See MoreIndia: Signs A further five unilateral advance pricing agreements
India's Central Board of Direct Taxes has entered into a further five unilateral advance pricing agreements (APAs). The APAs were signed on 27 October 2016 with Indian taxpayers operating in various sectors, including manufacturing and
See MoreMalaysia: Budget for 2017
The Malaysian Prime Minister announced Malaysia’s 2017 budget on 21 October 2016 highlighting some tax measures including corporate and personal income taxation changes. Highlighting proposals include important changes to the withholding tax
See MoreFinland: Income received from China on mobile games treated as royalties
The Finnish supreme administrative court issued an order that income on mobile games received by the Finnish company from the Chinese company, under the agreement, constituted royalties in accordance with the treaty. The issue in this case was
See MoreDenmark: Publishes main tax thresholds for 2010-2017
The Danish Ministry of Taxation published an overview of the tax thresholds applicable in the period from 2010-2017. The main amounts for 2017 are listed below: Corporate income tax: Amount (DKK) limit for the deduction of net financing
See MoreMexico: Publishes tax reform package for 2017
Mexico’s Government on 30 November 2016 Publishes the Decree containing the tax reform package for 2017 in the Official Gazette. The reform will be effective as of 1 January 2017. The main amendments to the income tax law are summarised
See MoreSweden: Submits proposals for the implementation of CbC reporting bill
Proposals for the implementation of country-by-country transfer pricing reporting have been submitted to Sweden's Council on Legislation alongside a draft law to transpose the updated EU Directive on administrative cooperation. According to an
See MoreSlovak Republic: Tax law amendments approved
Suggested amendments to corporate income tax, individual income tax, transfer pricing and special levies in case of companies in regulated industries has been approved by the parliament on 23rd November 2016. The amendments have not yet been
See MoreUS: TIGTA urged the IRS to ensure the protection of data the IRS transfers to external partners
The Treasury Inspector General for Tax Administration (TIGTA) in a final report issued November 3 concluded that transfer pricing issues are not being properly evaluated by the Internal Revenue Service because of various procedural barriers at the
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