India: CBDT publishes guidance on appropriate use of CbC reports
On 27 June 2018, the central board of direct taxes (CBDT) released Instruction No. 02/2018 to provide guidance on the appropriate use of CbC (Country-by-Country reports) reports. In 2015, the Organization for Economic Co-operation and Development
See MorePakistan: FBR extends tax amnesty scheme period to 31 July 2018
On 7 July 2018, the Federal Board of Revenue (FBR) approved an extension in tax amnesty scheme till 31 July 2018. Previously an ordinance was sent to the president of Pakistan for approval of the extension. The deadline for filing amnesty
See MoreIndia: CBDT publishes notification for taxation of foreign company held as resident in India as per POEM
On 22 June 2018, the Central Board of Direct Taxes (CBDT) has issued a final Notification No. 29/2018, dealing with special transitional provisions for a foreign company said to be a resident in India on account of Place of Effective Management
See MoreHong Kong: Legislative council passes the transfer pricing legislation
On 4 July 2018, the Legislative Council adopted the new transfer pricing regime ((Amendment) (No. 6) Bill 2017 (the “BEPS Bill”)). During the legislative process, some changes were made to the initial bill. Remarkable changes are the possible
See MoreThailand: Government submits the draft transfer pricing law to the National Legislative Assembly
On 5 June 2018, the Government submitted the draft of law amending the Revenue Code on transfer pricing to the National Legislative Assembly for approval. The draft law clarifies that taxpayers who meet the income threshold must prepare and submit
See MoreBangladesh: Parliament passes budget for FY 2018-19
On 28 June 2018, the Parliament of Bangladesh has passed the Tk 464,573 crore national budget for 2018-19 fiscal year. Finance Minister AMA Muhith moved the Appropriations Bill, 2018 seeking a budgetary allocation of Taka 571833,82,92,000 which was
See MoreThailand publishes various tax incentives
Thailand issued a series of Royal Decrees on 13 May 2018, which provide for various tax incentives. One of the main incentives is under Royal Decree No. 658, which extends the five-year corporation tax (exemption) for start-ups in certain target
See MoreIndia: CBDT proposes amendments to secondary adjustment rules for transfer pricing
On 20 June 2018, the Central Board of Direct Taxes (CBDT) has announced the publication of a draft notification for amendment in Rule 10CB of the Income-tax Rules, 1962 in respect of computation of interest income pursuant to secondary adjustment
See MorePakistan enacts Finance Bill 2018
The Finance Bill, 2018 was passed by the government on 22 May 2018, with some amendments. The Bill provides for the implementation of the measures proposed as part of the 2018-2019 Budget. The main measures are summarized as follows: Corporate
See MoreChina reduces tax rate for advanced technology service enterprises
China's Ministry of Finance has published a Circular 44/2018 for reducing corporate income tax rate of 15% (standard 25%) for advanced technology services enterprises with effect from 1 January 2018. This applies in particular for enterprises
See MoreAustralia: Draft PCG for Restructures of Hybrid Mismatch Arrangements
As part of the 2016-17 Federal Budget, the Australian government announced it would implement the Organisation for Economic Co-operation and Development's (OECD) Hybrid Mismatch rules developed under Action Item 2 of the OECD Base Erosion and Profit
See MoreIndia: No international transaction with related party in the absence of an agreement with the AE
Recently, the Mumbai Bench of the Income-tax Appellate Tribunal (the Tribunal) ruled its decision on the transfer pricing (TP) case of Colgate Palmolive (India) Ltd. v. ACIT (ITA No. 6073/Mum/2014 and ITA No. 2778/Mum/2011) in favor of the taxpayer.
See MoreIndia: The expenditure specifically incurred for Indian taxpayers’ market cannot be construed to benefit the AE
On 14 May 2018, the Delhi Bench of the Income-tax Appellate Tribunal ruled its decision on the transfer pricing (TP) case of BMW India Pvt. V. ACIT (ITA No 6160 / Del. / 2014) in favor of the taxpayer. The court held that, expenses that are
See MoreKazakhstan signs MCAA
On 12 June 2018, Kazakhstan signed the Multilateral Competent Authority Agreement (MCAA) on the automatic exchange of Country-by-Country (CbC) reports. Kazakhstan has not yet activated the CbC MCAA in accordance with OECD’s
See MoreAustralia updates international dealings schedule for 2018 tax year
The Australian Taxation Office (ATO) has released the 2018 International dealings schedule (IDS) and their instructions for 2018 tax years. The IDS must be lodged by businesses that provide a response at the trigger questions of the relevant
See MoreAustralia updates guidance on R&D tax offsets
The Australian Taxation Office (ATO) has published updated guidance concerning the rate of the Research and Development (R&D) tax offset and whether it is refundable under the R&D tax incentive. If aggregated turnover is less than AUD
See MoreBangladesh: Income Tax Proposal in Fiscal Budget 2018-2019
Finance Minister Mr. AMA Muhith presented the FY2018-19 national budget to parliament on 7th June 2018. Except for a minor downward tweaking of the corporate tax rate, and some small increases in tobacco taxation and supplementary import duties, no
See MoreJapan: Diet passes Bill on the Multilateral Instrument (MLI)
On May 18, 2018, the Japanese legislature passed the Bill on the Multilateral Instrument (MLI). This means that Japan has completed the national process of ratifying the MLI. The next step is for Japan to deposit its instrument of ratification,
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