Hong Kong: IRD revises practice notes on deduction of foreign taxes
In the middle of August 2019, the Hong Kong Inland Revenue Department (IRD) revised Departmental Interpretation and Practice Notes No. 28 regarding Deduction of Foreign Taxes (“DIPN 28”). The updated version replaced the one issued on 19 July
See MoreIndia: MLI enters into force
On 1 October 2019, the Multilateral Convention to Implement Tax Treaty Related Measures to Prevent Base Erosion and Profit Shifting (MLI) entered into force with respect of India. On 25 June 2019, India has deposited its instrument of ratification
See MoreIndia: ITAT ruled that the Liaison Office of Hitachi constitutes a PE
On 17 September 2019, the Delhi Bench of the Income Tax Appellate Tribunal (ITAT) in the case of: Hitachi High Technologies Singapore Pte Ltd vs. DCIT , held that a Liaison Office (LO) of Hitachi Technologies Singapore Pte Limited constituted a
See MoreHong Kong and Estonia sign new tax treaty
On 25 September 2019, the Secretary for Financial Services and the Treasury of Hong Kong and the Minister of Finance of Estonia signed a comprehensive avoidance of double taxation agreement (CDTA) in Tallinn, Estonia. The agreement sets out the
See MoreMalaysia withdraws withholding tax exemptions available to MSC Malaysia status companies
Malaysia Digital Economy Corporation Sdn Bhd (MDEC) has recently announced on its website that the withholding tax (WHT) exemption on certain types of income received by a non-resident company from an approved Multimedia Super Corridor (MSC)
See MoreThailand: BOI approves Thailand Plus incentive package
On 20 September 2019, Thailand Board of Investment (BOI) approved a set of new incentive measures aimed at attracting foreign business to relocate and expedite large-scale investment as well as strengthening workforce development. These new
See MorePhilippines: BIR issues guidelines for transfer pricing audits
The Bureau of Internal Revenue (BIR) has issued Transfer Pricing Audit Guidelines under Revenue Audit Memorandum Order (RAMO) No. 1-2019 on 20 August 2019, which provides standardized audit procedures and techniques in auditing taxpayers with
See MoreIndia cuts corporate tax rate for domestic companies
On 20 September 2019, the Government of India introduced the Taxation Laws (Amendment) Ordinance, 2019. According to the Ordinance, the government makes certain changes to the Income Tax Act of 1961 and the Finance Act (No 2) of 2019. The main
See MoreAustralia updates guideline for simplified transfer pricing record keeping options
On 11 September 2019, the Australian Taxation Office (ATO) released an updated version of Practical Compliance Guideline (PCG) 2017/2 concerning the eligibility criteria for applying simplified transfer pricing record keeping options for
See MoreIndia: CBDT issues Notification on transfer pricing arm’s length tolerance range
On 13 September 2019, the Central Board of Direct Taxes (CBDT) published Notification No. 64/2019, which sets a tolerance range for the variation between the arm’s length price and the transaction price for the 2019-20 assessment year. The
See MoreVietnam clarifies the limitation of the deductibility of loan interest expense for TP purposes
On 11 September 2019, the Department of Taxation of Ha Noi City issued Official Letter No. 71443/CT-TTHT providing clarification on the determination of loan interest costs. Under article 8 (3) of Decree No 20/2017 / ND-CP, the total loan
See MoreHong Kong: IRD updates penalty provisions for international tax
On 4 September 2019, the Hong Kong Inland Revenue Department updated its web page on penalty policies related to international tax matters, including fines and criminal penalties, for noncompliance with international tax obligations. The
See MorePhilippines: House approves CITIRA bill on final reading
On 13 September 2019, the House of Representatives approved House Bill (HB) No.4157, in its final reading, entitled "The proposed Law on Corporate Taxation and Incentive Rationalization (CITIRA)". This bill was officially called the Trabaho bill.
See MoreIndonesia: Finance Minister declares tax reform plan
On 3 September 2019, the Minister of Finance, Sri Mulyani Indrawati, announced Government’s tax reform plan through a draft bill. The draft bill proposed following measures: Gradual decrease in corporate rate from 25% to 20% starting from
See MoreChina introduces several incentives for Lingang in Shanghai FTZ
On 6 August 2019,, China announced that it has added the Lingang area to the China (Shanghai) Pilot Free Trade Zone (FTZ) to enhance investment and advance trade liberalization with plans to replicate the concept nationwide, senior officials said.
See MoreTaiwan: MOF approves regulation on repatriation of offshore funds
On 15 August 2019, Taiwan's Ministry of Finance (MOF) has approved regulations on repatriation, use and taxation of offshore installations in order to guide China's personal and for profit business funds to return to Taiwan to invest in physical
See MoreHong Kong: IRD designs a webpage explaining the requirements of master file and local file
On 28 August 2019, the Hong Kong Inland Revenue Department published a webpage explaining the requirements in relation to master file and local file, and the Department’s approach to ensure compliance with the requirements. The webpage
See MoreMalaysia releases digital services tax guide
On 20 August 2019, the Royal Malaysian Customs Department published a service tax guide on digital services. The purpose of the guide is to provide a general understanding of the relevant treatment under Sales Tax and Services Tax Legislation and
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