India: CBDT signs two new APAs
On 6 October 2017, the Ministry of Finance issued a press release announcing that the Central Board of Direct Taxes (CBDT) has signed two more advance pricing agreements (APAs) in September 2017 with Indian taxpayers. These two latest APAs relate to
See MoreIndia: CBDT issues first comprehensive report on APA
On May 1, 2017, the first annual report on APA programme was released by the Central Board of Direct Taxes (CBDT) which provides various statistical and qualitative aspects of the Indian APA program to promote discussions and discussions between
See MoreIndia: CBDT signs four more unilateral APAs
On 6th February 2017, the Central Board of Direct Taxes (CBDT) has signed four more unilateral advance pricing agreements (APAs) with Indian taxpayers in order to reduce litigation by providing certainty in transfer pricing. The international
See MoreMalaysia: Corporate tax proposals under the finance act 2016
The Finance Act 2016, which was gazetted on 16 January 2017, introduces new corporate tax proposals to the Malaysian Income Tax Act (MITA). The highlighted area of the proposals is as given below; Special classes of income are subject to withholding
See MoreSlovenia: Publishes advance pricing agreement rules
Details on the introduction of Advance Pricing Arrangements (APAs) are now available in the Official Gazette on 28 December 2016. Accordingly, the following rules will apply from January 2017: (i) The application of APA must be addressed to the
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 MoreSlovak Republic: Introduction to country-by-country reporting
The legislative bodies of Slovakia has issued a bill amending Act No. 442/2012 Coll. on international assistance and cooperation in tax administration that introduces the country-by-country (CbC) reporting obligation in Slovakia. The draft
See MoreSlovak Republic: Tax law amendments proposed
A governmental package of proposed amendments on tax law has been submitted to the parliament and the changes are suggested to become effective from 1st January 2017. These changes needs to be approved by the parliament and signed by the President
See MoreEuropean Commission to investigate Luxembourg tax rulings
On 19 September 2016 the European Commission announced that it is commencing an investigation into the tax treatment of GDF Suez Group (now known as Engie) in tax rulings issued by Luxembourg. The tax rulings may in the view of the Commission have
See MoreItaly: Tax Authorities Issue Regulation to Clarify APA Procedure
The director of the Italian Revenue Office (Agenzia delle Entrate) issued regulation no. 42295/2016 (the regulation) on March 21 2016 which contains provisions for the application of the rules on advance pricing agreements (APAs) for enterprises
See MoreIreland: Advance pricing agreement regime announced
The Irish revenue authority has announced that it will introduce a formal Advance Pricing Agreement (APA) program and are expected to be published in 2016. Ireland has accepted and concluded bilateral advance pricing agreements (APAs) for many years
See MoreTaiwan: Simplifies the conditions for the application of advance pricing agreement
The Ministry of Finance has simplified the conditions for the application of an advance pricing agreement (APA) and other procedural rules based on the amendments enacted on 6 March 2015. Accordingly, a taxpayer may apply for an APA if the total
See MoreRomania: Government publishes new Orders on tax rulings and APAs
The Romanian Government published Orders at the end of 2015 regarding binding tax rulings and advance pricing agreement (APAs). Under the provisions on binding tax rulings the tax situation that is to be the subject of the ruling must be in the
See MoreNetherlands: Decree published on adjustment period for advance tax rulings issued
During the parliamentary debate on the Act implementing the changes Parent-Subsidiary Directive 2015 have been in the Memorandum relating to the report two indicated publish a policy decision on an adjustment period for advance tax rulings
See MoreIndia: Extends Time for Filing Roll-back Applications under APA
The Central Board of Direct Tax authorities announced that the deadline for filing APA (Advance Pricing Agreement) rollback applications has been extended to 30 June 2015. Originally, the date for filing rollback applications was 31 March
See MoreIndonesia: Releases Regulation on New Advance Pricing Agreement
The Ministry of Finance in Indonesia has released regulation No. 7/PMK.03/2015 (PMK-07) on the implementation of advanced pricing agreements (APAs). The guidance on the processes is provided in PMK-07. PMK-07 states that the Directorate General of
See MoreMalaysia: IRB Issues Public Ruling On Qualifying Plant And Machinery For Claiming Capital Allowances
The Inland Revenue Board of Malaysia (IRBM) released a public ruling (No.12/2014) on qualifying plant and machinery for claiming capital allowances on December 31, 2014. The objective of this Public Ruling (PR) is to explain whether an asset is a
See MoreMalaysia: IRB Issues Public Ruling On Small Asset Tax Allowance
The Inland Revenue Board of Malaysia (IRBM) has issued a new public ruling providing guidance on the 100 percent special allowance afforded to businesses for capital expenditure incurred on their purchase of small value assets. The objective of this
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