Australia: ATO issues draft schedule concerning cross border related party financing arrangements
On 1 August 2018, the Australian Taxation Office (ATO) issued a draft Schedule 2 to PCG 2017/4 for public consultation. This guidance addresses the ATO’s compliance approach to taxation issues associated with cross border related party
See MoreAustralia: Improving the integrity of the thin capitalization rules
The Australian Government announced that it will implement two changes to improve the integrity of Australia’s thin capitalization rules in the 2018-19 Budget. The changes are: requiring entities to align the value of their assets for thin
See MoreKorea: MOEF proposes tax revision bill for 2018
On 30 July 2018, South Korea's Ministry of Economy and Finance (MOEF) has issued an overview of the proposed 2018 Tax Revision Bill for strengthening social welfare and bringing about redistribution of income, promoting job creation and growth
See MoreKorea announces tax law amendments proposal for 2019
On 30 July 2018, the Ministry of Strategy and Finance (MOSF) announced its proposed tax law amendments proposal for 2019. This rule will be effective as from tax years beginning on or after 1 January 2020. The summary of the tax amendments proposal
See MoreThailand approves an amendment of tax incentive in response to BEPS Action 5
The Thai Cabinet approved an amendment of the tax incentive criteria on 19 June 2018 for the International Headquarters (IHQs) seemingly in response to BEPS Action 5. It limits types of qualified royalty income to only those that are for the result
See MoreChina increases loss carry forward period for HNTEs and TSMEs
The Ministry of Finance of China has published a Circular 76/2018 extending the current 5-year loss carry forward period to 10 years for High-and-New Technology Enterprises (HNTEs) and Technology-based Small and Medium-sized Enterprises (TSMEs).
See MoreNew Zealand-Sweden: Deposit ratification instrument for BEPS MLI
New Zealand and Sweden deposited their ratification certificates on 27th June and 22nd June 2018, respectively for the multilateral agreement on the implementation of tax-relevant measures to prevent erosion and profit shifting (MLI). The MLI will
See MoreIndia: CBDT signs first ever substantive revision to India-UK Bilateral APA
Recently, the Central Board of Direct Taxes (CBDT) signed the first ever substantive revision to an India-U.K. Bilateral advance pricing agreement (APA) due to certain changes in the way a particular transaction was being conducted. The changes were
See MoreNew Zealand’s taxation act regarding Neutralising Base Erosion and Profit Shifting receives royal assent
New Zealand's Taxation (Neutralising Base Erosion and Profit Shifting) Act received royal assent on 27 June 2018. The main measures of the Act are summarized as follows: CbC reporting requirement: According to the published guidance on
See MoreU.S. and Indonesia sign an agreement on the exchange of CbC reports
According to an IRS announcement on its website, the competent authorities of the U.S. and Indonesia have concluded an arrangement on the exchange of Country-by-Country Reports. The competent authority arrangement (CAA) for exchange of
See MoreChina declares tax incentive for small enterprises
State Administration of Taxation (SAT) of China has published Circular 77/2018 to extend the tax incentive for small and low-profit enterprises. The incentive provides for a 50% reduction in taxable income with a reduced tax rate of 20%. From
See MoreAustralia: New guidelines for Local and Master file for 2018
The Australian Taxation Office (ATO) has published Local file instructions 2018 and Local file/master file 2018 to provide guidance for taxpayers to comply. The local file must be electronically lodged in the approved form (an XML file generated
See MoreAustralia: ATO publishes draft guidance on transfer pricing issues
The Australian Taxation Office (ATO) has issued Draft Schedule 2 to Practical Compliance Guideline (PCG) 2017/1 ATO compliance approach to transfer pricing issues related to centralized operating models involving procurement, marketing, sales and
See MoreIndia: 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
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