Australia: ATO implements the OECD hybrid mismatch rules
In the 2016–17 Budget, the Australian government announced it would implement the Organisation for Economic Cooperation and Development (OECD) hybrid mismatch and branch mismatch rules from Action Item 2 of the OECD Base Erosion and Profit
See MoreIndia: CBDT signs first APA renewal
On 31 October 2018, the Central Board of Direct Taxes (CBDT) has signed a unilateral advance pricing agreement (APA) renewal. Accordingly, India reached another milestone as the first ever renewal of a unilateral APA. This renewal establishes
See MoreIsrael deposits its MLI Ratification Instrument
The Organization for Economic Co-operation and Development (OECD) announced on September 13, 2018 that Israel deposited its instrument of ratification to implement the Multilateral Convention to Implement Tax Treaty Related Measures for preventing
See MorePakistan: SECP publishes requirements for companies to maintain record of all related party transactions
On 2 October 2018, the Securities and Exchange Commission of Pakistan (SECP) has issued SRO 1194(I)/2018 to introduce Companies (Related Party Transactions and Maintenance of Related Records) Regulations, 2018. These Regulations are applicable on
See MorePhilippines: House of Representatives approves corporate tax reform bill
On 10 September 2018, the House of Representatives approved the Tax Reform for Attracting Better and Higher Quality Opportunities (Trabaho) bill 8083 (the Bill). Under the bill, the corporate tax rate will be gradually reduced by 2% every 2 years
See MoreAustralia updates MAP guidance
The Australian Taxation Office (ATO) has updated its guidance on the mutual agreement procedure (MAP) framework contained in tax treaties to resolve disputes. The new guidance represents an update on Taxation Ruling TR 2000/16 Income tax:
See MoreThailand: National Legislative Assembly publishes revised draft transfer pricing act
On 27 September 2018, National Legislative Assembly released the revisions to the draft Transfer Pricing Act (the draft TP Act). The revenue threshold for subject to transfer pricing documentation is THB200 million (US$6 million) per year
See MoreAustralia: ATO publishes Diverted profits tax guidance
The Australian Tax Office (ATO) published the final form of the Practical Compliance Guideline (PCG) 2018/5 Diverted profits tax (DPT) and Law Companion Ruling (LCR) 2018/6 Diverted profits tax. The PCG aims to assist affected clients and their
See MoreIsrael and Lithuania both complete ratification of BEPS MLI
Israel and Lithuania have ratified a multilateral convention to implement tax treaty related measures to prevent BEPS (MLI). This means that both countries have completed the domestic process and deposit its ratification instrument for MLI. This
See MoreKazakhstan: Resolution No. 528 of 27 August 2018 publishes for amending APA process
According to Resolution No 528 of 27 August 2018 published on 6 September 2018, the review committee must complete its review within 60 working days of receipt of the application. If the application is approved, the signed contract should be sent to
See MoreIsrael: Tax Authority publishes Circulars regarding transfer pricing issues
The tax authorities (ITA) have recently published final versions of two professional Circulars, entitled Circular 11/2018 and Circular 12/2018, stating the ITA's expected profit levels for marketing services and for low-risk distributorship
See MoreIndia: CBDT publishes second APA annual report
The Central Board of Direct Tax (CBDT) released the second annual report (2017-18) of its advance pricing agreement (APA) programme on 31 August 2018. The report introduced a report card of the performance of the programme along with qualitative and
See MoreASEAN: Agreements Signed at Meeting of Economic Ministers
Economic Ministers from member states of the Association of South East Asian Nations (ASEAN) are meeting in Singapore between 29 August and 1 September. A number of important economic agreements have been signed or endorsed by the Ministers. AFAS
See MoreAustralia: Eligibility changes for the lower corporate tax rate
Changes to the lower corporate tax rate are now law. This means the definition of a base rate entity has changed by replacing the 'carrying on a business' requirement with a passive income test. From the 2017–18 income year, a corporation will be
See MoreAustralia: Parliament adopts hybrid mismatch legislation
On 16 August 2018, Treasury Laws Amendment (Tax Integrity and Other Measures No. 2) Bill 2018 containing the hybrid mismatch integrity measures was passed by the Parliament. The bill includes the measures to prevent entities that are liable to
See MoreHong Kong signs multilateral competent authority agreement on exchange of CbC reports
Hong Kong joined the multilateral competent authority agreement on the exchange of country-by-country reports (CbC MCAA). The CbC MCAA was signed by Hong Kong on 27 July 2018. The purpose of the CbC MCAA is to set forth rules and procedures as may
See MoreKazakhstan: Ministry of Finance releases draft bill to ratify MLI
The Finance Ministry has published a draft bill on August 1, 2018, for ratifying the Multilateral Convention to Implement Tax Treaty Related Measures to Prevent BEPS (MLI). Generally, for a particular covered agreement, the MLI will enter into force
See MoreSingapore: IRAS publishes e-tax guide on country-by-country reporting
On 7 August 2018, the Inland Revenue Authority of Singapore (IRAS) published the third edition of its e-Tax Guide concerning country-by-country reporting. The purpose of the guide is to provide information to the taxpayers regarding the obligation
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