China: Larger scale tax cuts for small and micro businesses
On 9 January 2019, China's State Administration of Taxation and Ministry of Finance have jointly issued Notice 13/2019 declaring additional tax relief for small businesses and changes for the investment incentive in start-ups approved by the State
See MoreSingapore deposits ratification instrument for MLI
On 21 December 2018, Singapore deposited its instrument of ratification of the Multilateral Agreement for the Implementation of Measures relating to the Prevention of Erosion and Profit Shifting (MLI). As of 21 December 2018, a total of 18 countries
See MoreIndonesia approves new foreign tax credits rules
On 9 January 2019, Indonesia's Directorate General of Taxation published new regulation (No. 192/PMK.03/2018) regarding foreign tax credits. The new regulations update and replace prior regulations and generally apply in respect of foreign income
See MoreAustralia: ATO updates guidelines of STPRK options
The Australian Taxation Office (ATO) has recently updated Practical Compliance Guideline (PCG) 2017/2 Simplified transfer pricing record-keeping (STPRK) options. The PCG outlines transaction types or activities identified as low risk for
See MoreKorea Rep. enacts tax reform bill for 2019
On 24 December 2018, Korea enacted the 2019 tax reform bill after it was passed by Korea’s National Assembly on 8 December 2018. The 2019 Tax Reform also includes provisions in line with the OECD BEPS Action Plan 7 among others. The 2019 Tax
See MoreThailand implements IBC regime in line with OECD inclusive framework for BEPS
On 28 December 2018, Thailand published a Royal Decree regarding implementation of the International Business Center (IBC) regime in the Official Gazette and became effective as of 29 December 2018, which replaces the International Headquarters
See MoreMalaysia: Parliament passes Finance bill 2018 (Budget 2019)
On 10 December 2018, the House of Representatives passed the Finance Bill 2018 which was published in the Federal Gazette on 27 December 2018. The key changes of Finance Bill 2018 are summarized below: Corporate Tax Changes The limitation
See MoreJapan: MLI enters into force
On 1 January 2019, the Multilateral Convention to Implement Tax Treaty-Related Measures to Prevent BEPS (‘Multilateral Instrument’ or ‘MLI’) entered into force in respect of Japan. The MLI was signed by Japan on 7 June 2017. As of 1 October
See MoreJapan proposes tax reform plans for 2019
On 14 December 2018, Japan's ruling coalition party has approved a package of tax reform proposals for 2019. The proposal includes amendments to Japan’s controlled foreign company (CFC), interest expense limitation, and general transfer pricing
See MoreIndia: Ministry of Finance issues CbC report extension deadline
On 26 December 2018, India’s Ministry of Finance released a Circular, which provides for an extension of the deadline for non-parent constituent entities in India to submit a Country-by-Country (CbC) report where secondary local filing is
See MoreDTA between India and Hong Kong enters into force
On 30 November 2018, the tax treaty between India and Hong Kong entered into force and the treaty will be effective from 1 April 2019. The tax treaty provides for a low withholding tax rate of 5% for dividend payments. Interest, royalties, and fees
See MoreThailand: New Transfer Pricing Law effective from January 2019
On 21 November 2018, the Transfer Pricing Act of Thailand was published in the Royal Gazette and will be effective for accounting years beginning on or after 1 January 2019. Taxpayers with related parties, regardless of having related-party
See MoreSingapore enacts the Income Tax (Amendment) Act 2018
On 12 November 2018, Singapore enacted the Income Tax (Amendment) Act 2018. The Act(amended) implements the changes in income tax announced in the 2018 budget statement and changes in the taxes resulting from the regular review of income tax
See MoreVietnam: NFSC proposes to cut the corporate income tax on SMEs
The National Financial Supervisory Committee (NFSC) has proposed cuts to corporate income tax for small-and-medium sized enterprises to promote their development. This was a highlighted in the January-September fiscal and budget report by the
See MoreVietnam considering amendments to rules that limit related-party interest deductions
According to recent reports, the Vietnam Ministry of Finance is considering proposed amendments to the country's interest expense deduction restriction. The Decree No. 20/2017/ND-CP, enacted 24 February 2017 (Decree 20), limits deductions
See MoreChina: CbC reporting requirement for certain outbound MNCs alleviated
China has initiated country-by-country (CbC) reporting and exchange relationships with 44 countries. China expands current exchange relationship with the UK, France, and Germany. For Chinese outbound multinational companies (MNCs), the expanded CbC
See MoreAustralia: ATO extends deadline to file CbC reports
Significant Global Entities (SGE) that have a Country-by-Country (CbC) reporting obligation for the year ended 31 December 2017 will be aware that the Local file, Master file, and CbC report are due to be lodged by 31 December 2018. However, due
See MoreThailand enacts Transfer pricing law
On 21 November 2018, Thailand's new transfer pricing law was enacted and published in the Official Gazette and will be effective from 1 January 2019, which was approved by the National Legislative Assembly in 27 September 2018. Tax assessment
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