India and USA sign inter-governmental agreement for exchange of CbC reports
On 27 March 2019, India and the US signed an Inter-Governmental Agreement for exchange of Country-by-Country (CbC) reports of multinational companies regarding income allocation and taxes paid to help check cross-border tax evasion. This
See MoreHong Kong: IRD extends Country by Country (CbC) reporting notification
On 21 March 2019, the Inland Revenue Department (IRD) published an announcement of extending CbC notification in respect of the accounting period beginning 1 January 2018. Under this, the notification deadline for accounting period beginning 1
See MoreIndia: ITAT ruled that the income which is deemed to accrue or arise in India must have a territorial nexus
Recently, the Mumbai Bench of the Income-tax Appellate Tribunal (ITAT) in the case of: Fox International Channel Asia Pacific Ltd v. DCIT (ITA No.1947/Mum/2015) regarding the taxability of agency commission relating to the services rendered outside
See MoreIndia: ITAT decision on criteria for selecting transfer pricing comparable companies
The Kolkata Bench of the Income Tax Appellate Tribunal (ITAT) in the case of: Philips Medical Systems (P.) Ltd. v. ITO, held that an entity engaged in both manufacturing and trading activities cannot be a comparable company for benchmarking the
See MoreAustralia: New guidance related to inbound distribution arrangements
On 13 March 2019, the Australian Taxation Office (ATO) released a PCG 2019/1 for all multinational enterprises (MNEs) with distribution operations in Australia. This Guideline outlines compliance approach to the transfer pricing
See MorePakistan approves the Finance Supplementary (Second Amendment) Bill, 2019
On 6 March 2019, the National Assembly has approved the Finance Supplementary (Second Amendment) Bill, 2019 aimed at amending tax laws. The major changes introduced to income tax laws are as follow: -For nonbanking sectors, the super tax is
See MoreChina: New rules and requirements for tax compliance
Recently promulgated Chinese tax regulations include following changes affecting corporate income tax: Increase to the unit value of fixed assets eligible for the “one-off deduction method” to RMB 5 million;Increase to the deduction limit
See MoreChina aims to reduce taxes in 2019
On 5 March 2019, Mr. Li Keqiang, the Premier declared that the Chinese government is planning to reduce CNT 2 trillion in taxes and fees for companies during 2019. He also included that the government is planning to reduce Value Added Tax (VAT)
See MoreTaiwan: NTBNA publishes Guidance on Submission of TP documentation
On 26 February 2019, National Taxation Bureau of the Northern Area (NTBNA), Ministry of Finance of Taiwan has published guidance on the submission of the Master file and Country-by-Country report by MNEs. Here are the key points as follows: The
See MoreTaiwan: NTBND Publishes a clarification on carry forward of losses for exemption from investment income
On 4 March 2019, the National Tax Bureau of the Northern District (NTBND) of the Ministry of Finance of Taiwan issued a clarification on carry-forward of losses for exemption from investment income. Under the clarification following changes
See MoreDTA between Azerbaijan and Turkmenistan enters into force
On 12 February 2019, the parliament of Azerbaijan approved the Double Taxation Agreement (DTA) with Turkmenistan for the avoidance of double taxation and the prevention of fiscal evasion with respect to taxes on
See MoreHong Kong: Financial Secretary presents 2019/2020 Budget
On 27 February 2019, the Financial Secretary has presented the 2019-20 budget to the Legislative Council. The Budget measures includes the following: -Reducing profits tax by 75% for 2018/19, subject to a ceiling of HKD20,000, effectively giving
See MoreHong Kong: IRD publishes 2018/19 profits tax returns and supplementary forms
On 18 February 2019, the Hong Kong Inland Revenue Department (IRD) has published the sample Profit Tax Returns for 2018/2019 including new Transfer Pricing Disclosure Form and other supplementary forms. The supplementary forms are also provided for
See MoreSingapore presents Budget for 2019
On 18 February 2019, the Finance Minister of Singapore delivered the Budget for 2019. The main tax-related measures are summarized below: To maintain support to companies in their automation, productivity and scale-up efforts, the 100%
See MoreHong Kong: IRD plans to close voluntary filing of CbC report from 1 April 2019
On 1 February 2019, Hong Kong Inland Revenue Department (IRD) announced that effective from 1 April 2019, the department will not accept voluntary filing of a CbC Return for an accounting period ended on or before 31 March 2018. Under section 58E(2)
See MoreIndia: Finance Minister presents Budget for 2019-20
On 1 February 2019, Finance minister Piyush Goyal presented the much awaited Union Budget in Lok Sabha. Goyal was appointed interim finance minister on January 23 with Arun Jaitley undergoing treatment in the United States. Some of the main measures
See MoreKazakhstan: New guidelines of TP Documentation and APA
On 24 December 2018, Mr. Alikhan Smailov, the Finance Minister of Kazakhstan approved forms and procedures for filling the Master files and Local files, effective from January 01, 2019. Generally, the rules for Master file and Local file are in line
See MorePakistan: Finance Supplementary (Second Amendment) Bill submits in Parliament
On 23 January 2019, Pakistan’s draft Finance Supplementary (Second Amendment) Bill, 2019 was submitted to the National Assembly. The finance minister clarified that, "This is not a budget, this is a corrective package aimed at addressing various
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