Australia: Minimum interest rate for simplified transfer pricing record keeping for 2018
The Australian Taxation Office (ATO) has updated its guidance on simplified transfer pricing record keeping options to include the minimum interest rate for the simplified option for low-level outbound loans for the 2018 income year, which is set at
See MoreKorea: Imposed limitation on expense deductions relating to hybrid financial instruments
The 2018 Tax Reform introduces a limitation on deductible expenses relating to hybrid mismatch arrangements as a commitment to implement the hybrid mismatch rules recommended by the Organisation for Economic Co-operation and Development’s. The
See MoreSerbia: Ministry of Finance updates rulebook on arm’s length interest rates for 2018
The Serbian Ministry of Finance has updated the rulebook concerning arm’s length interest rates. The Rulebook was published in the Official Gazette of Serbia No. 18/2018 dated 9 March 2018. The Rulebook contains the prescribed interest rates
See MoreAustralia: Implementing the OECD Hybrid Mismatch Rules
The Australian Government announced in the 2016-17 and 2017-18 Budgets that it would implement the Organisation for Economic Co operation and Development’s (OECD) rules aimed at eliminating double non-taxation benefits from hybrid mismatch
See MoreNetherlands: Dutch Council of Ministers approves fiscal policy agenda
The Council of Ministers approved the fiscal policy agenda on a package to combat tax avoidance and tax evasion. The most important changes are summarized below: Corporate Income Tax (CIT) rate: According to the Agenda, the current standard Dutch
See MoreCzech Republic: Proposed amendments to income tax for 2019
Recently, Finance Ministry has published the first draft copy of the amendment to the Income Tax Act for comments. These amendments are supposed to be started from year 2019. The proposed personal income tax rate of 19% is 1.1% less than the present
See MoreAustralia: Guidelines on attribution of ADI equity capital and controlled foreign entity equity
On 24 January 2018, the Australian Taxation Office (ATO) issued the Practical Compliance Guideline (PCG) 2018/1. This Guideline sets out how the ATO will administer subsection 820-300(3) of the Income Tax Assessment Act 1997 (ITAA
See MoreFinland:Ministry of Finance publishes draft bill on deduction of interest payment
On January 19, 2018, the Finnish Ministry of Finance published a draft government bill containing proposed changes on the deduction of interest paid to related parties. The Ministry of Finance has requested comments from interested parties by the
See MoreSlovak Republic: Government approves several tax amendments
The President has signed an amendment to Law No. 595/2003 Coll. on Income Tax on December 20, 2017. Some of the changes are given below: Related party transaction In accordance with the current amendment, the text of the related party definition
See MoreKorea Rep OF: Legislation of Tax Reform Bill 2018
On 19 December 2017, Korea passed the 2018 Tax Reform Act (the 2018 tax reform) after it was passed by the Korean National Assembly on 5 December 2017. The tax reform 2018 contains provisions in line with the BEPS Action 2 and Action 4 of the OECD.
See MoreAustralia: Final guideline on cross-border related-party financing arrangements
The Australian Taxation Office (ATO) has published the final Practical Compliance Guideline PCG 2017/4 on its compliance approach to cross-border related financing arrangements. The guidance explains how taxpayers can price related party loans to
See MoreArgentina: Comprehensive tax reform enacts
The Law No. 27430 or comprehensive tax reform was published on December 29, 2017 in the Official Gazette and it generally applies from January 1, 2018. This comprehensive tax reform bill has sent to Congress on December 14, 2017. The Ministry of the
See MoreNew Zealand: A tax bill to counter tax avoidance introduces into Parliament
On 6 December 2017, a tax bill to counter tax avoidance has been introduced into New Zealand’s Parliament by multinational companies and Minister of Revenue also published its commentary on the bill. Most provisions would enter into effect July
See MoreAustralia releases draft legislation to address hybrid mismatch
24 November 2017, Australia’s Treasurer released exposure draft legislation to address hybrid mismatch arrangements reaffirms the Turnbull Government’s continued focus on strengthening the integrity of Australia’s tax system, and stamping out
See MoreUK enacts interest restriction rules
On 16 November 2017, the new corporate interest restriction rules were enacted in Finance (No.2) Act 2017 that received Royal Assent to impose an additional potential restriction on UK tax relief for finance costs, after the existing tax rules
See MoreNetherlands: The new Dutch Government publishes Policy Paper
The new Dutch government published its Policy Paper on 10th October 2017. The paper highlights the policy of the new Dutch government for the next four years. The new four-party coalition government was formed after extensive negotiations after the
See MoreJersey: Draft Budget 2018 Published
The Government published the Draft Budget 2018 on October 3, 2017. This budget constructs the package of measures agreed in the Medium Term Financial Plan (MTFP), combining savings, efficiencies and revenue raising measures to enable investment in
See MoreUK: Second Finance Bill of 2017 published
On 8 September 2017 the UK government published the second Finance Bill of 2017. This second Finance Bill was necessary because not all the legislative changes announced in the autumn statement 2016 and budget proposals for 2017 could be included in
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