Malaysia announces principal hub incentive
On 8 October 2019, the Malaysian Investment Development Authority ("MIDA") announced enhancements to its headquarters hub tax incentive. From a tax point of view, Principal Hub companies are classified on the basis of their level of
See MoreIndia: Finance Minister introduces Taxation Law (Amendment) Bill, 2019
On 25 November 2019, the Finance minister Nirmala Sitharaman introduced the Taxation Laws (Amendment) Bill, 2019 in the lower house of Parliament (Lok Sabha). The Amendment Bill will replace Taxation Laws (Amendment) Ordinance, 2019, which aims to
See MoreTaiwan: MOF clarifies the procedures for one-time transfer pricing adjustments
On 15 November 2019, the Ministry of Finance issued a ruling no.10804629000 providing the guidance when multinational enterprises (MNEs) make a one-time transfer pricing adjustment to achieve an arm’s length result. For making one-time
See MoreNew Zealand: Inland Revenue updates its compliance focus on MNEs
On 1 November 2019, the Inland Revenue has published a document setting out its compliance focus in respect of Multinational Enterprises (MNEs). The document aimed to make tax compliance more transparent for businesses and provide transparency and
See MoreAustralia extends TP document submission deadline
Significant global entities (SGEs) that have a CbC reporting obligation in Australia for the year ended 31 December 2018 required that their local file (LF), master file (MF), and CbC report are due to be lodged by 31 December
See MoreKazakhstan: Lower house of parliament approves ratification of BEPS MLI
On 30 October 2019, the lower house of Parliament (Mazhilis) approved the ratification of the Multilateral Agreement on the Implementation of Tax Treaty Related Measures to Prevent Base Erosion and Profit Shifting (MLI). It was approved by the
See MoreVietnam clarifies the tax implications of interest income
On 24 October 2019, the Tax Authority issued an official letter (No. 80503 / CT-TTHT) explaining the tax implications of interest income on term loans. The letter clarifies that loan interest earned in Vietnam is subject to withholding tax. The
See MoreNew Zealand: Inland Revenue clarifies about BEPS disclosure requirement
Recently, the New Zealand's Inland Revenue has introduced the Base Erosion and Profit Shifting (BEPS) disclosure requirement to support the new BEPS rules, including the expanded information collection powers applying to large multinational groups.
See MoreHong Kong publishes an order to implement the tax agreement with Estonia
On 9 October 2019, the Hong Kong’s Chief Executive in Council made an order under the Inland Revenue Ordinance (Cap. 112) to implement the Comprehensive Avoidance of Double Taxation Agreement with Estonia (Estonia CDTA) that was signed on 25
See MoreHong Kong publishes an order to implement protocol with Mainland (China)
On 2 October 2019, the Hong Kong’s Chief Executive in Council made an order under the Inland Revenue Ordinance (Cap. 112) to implement the Fifth Protocol to the Comprehensive Avoidance of Double Taxation Arrangement with the Mainland (Mainland
See MoreHong Kong publishes an order to implement the tax agreement with Cambodia
On 2 October 2019, the Hong Kong’s Chief Executive in Council made an order under the Inland Revenue Ordinance (Cap. 112) to implement the Comprehensive Avoidance of Double Taxation Agreement with Cambodia (Cambodia CDTA) that was signed on 26
See MoreMalaysia: IRBM issues income tax penalties for late return
On 16 October 2019, the Inland Revenue Board of Malaysia issued Operational Guideline No. 5/2019, which sets out the penalties for taxpayers who fail to file the tax returns within the prescribed timelines under the Income Tax Act 1967, the
See MoreTaiwan: MOF issues tax ruling on Taiwan-sourced income of foreign entities
On 26 September 2019, Taiwan’s Ministry of Finance (MOF) released a tax ruling regarding the new method of calculating income source from Taiwan originating from foreign entities amending article 15-1 in accordance with Article 8 of the Income
See MoreMalaysia: Finance Minister presents the budget for 2020
Malaysia's Minister of Finance tabled in parliament the Budget for 2020. The budget provides the following tax measures: The SME income tax rate for Chargeable Income up to the first RM500,000 was reduced by 1% to 17% in 2019. To further
See MoreIndia: CBDT amends rules to calculate interest income relating to Secondary Adjustments
On 30 September 2019, the Central Board of Direct Taxes (CBDT) has amended rule 10CB which provide for computation of interest income relating to secondary adjustments. The changes remove anomalies and clarify the compliance and computational
See MoreHong 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
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