Korea: Imposed limitation on expense deductions relating to hybrid financial instruments
The 2018 Tax Reform introduces a limitation on deductible expenses relating to hybrid mismatch arrangements as a commitment to implement the hybrid mismatch rules recommended by the Organisation for Economic Co-operation and Development’s. The
See MoreKorea: Increased noncompliance penalties on transfer pricing documentation requirement
Korea has increased noncompliance penalties on transfer pricing documentation requirement. Taxpayers who fail to file a Combined Report of International Transactions (CRIT) or file false information are subject to penalties of KRW10 million
See MoreSingapore: New transfer pricing rules
Singapore Inland Revenue Authority published transfer pricing documentation rules and transfer pricing guidelines in February 2018. The major expansions of the transfer pricing rules are as follows: The arm’s length principle is aligned with
See MoreKorea: Important changes in tax rules
The Korean Ministry of Strategy and Finance released amendments to the tax law on 13 February 2018. Key changes are following: The withholding tax rate will increase from 17% to 19% on the amount of compensation paid to hiring foreign entities.
See MoreAustralia: Closing tax consolidation loopholes
On 22 March 2018, the Australian Government’s commitment to ensure multinationals pay the right amount of tax in Australia continued with the passage through Parliament of the Treasury Laws Amendment (Income Tax Consolidation Integrity) Bill
See MoreIndian APA accepts customs valuation as arm’s length price for transfer pricing
Recently, the Central Board of Direct Taxes (CBDT) has entered into an advance pricing agreement (APA) where the price determined by the Indian Customs authorities was accepted as arm’s length price for import transactions for transfer pricing
See MoreIndia : Finance Bill 2018 approves by Lower House
On 14 March 2018, the lower house (Lok Sabha) of parliament passed the Finance Bill 2018 with modifications. The modifications agreed by the lower house includes: -The Budget 2018 had introduced tax at 10% on LTCG of more than Rs 1 lakh, arising on
See MoreChina: Tax reforms for 2018
China’s thirteenth National People’s Congress and the Chinese People’s Political Consultative Conference are holding meetings during 3 to 20 March, 2018. A number of regulatory and tax reforms have been announced. The tax reduction for 2018
See MoreOECD: Third round of peer reviews on dispute resolution mechanisms
On 12 March 2018 the OECD released the third round of peer reviews relating to improving tax dispute resolution mechanisms to make them more timely, relevant and effective. Action 14 of the action plan on base erosion and profit shifting (BEPS) was
See MoreIndia: The deadline for multinationals to submit a master file and CbC report is 31 March
The due date for multinationals in India to furnish a country-by-country (CbC) report and masterfile for the accounting year 2016-17 is 31 March 2018. The master file must be submitted on Form 3CEAA. Part A of the form is required for all
See MoreIndia: CbC reporting changes made in Finance Bill 2018 as passed by the Lok Sabha
On 14 March 2018, the lower house of parliament (Lok Sabha) has approved the Finance Bill 2018 with modifications. One of the main changes includes by the bill is changes to the country-by-country (CbC) reporting and Master file requirements. The
See MoreAustralia: Implementing the OECD Hybrid Mismatch Rules
The Australian Government announced in the 2016-17 and 2017-18 Budgets that it would implement the Organisation for Economic Co operation and Development’s (OECD) rules aimed at eliminating double non-taxation benefits from hybrid mismatch
See MoreHong Kong introduces CbC reporting portal
On 5 March 2018, Hong Kong government announced that it has launched its country-by-country reporting portal. Hong Kong Ultimate Parent Entities of Reportable Groups (HK UPEs) can now file CbC Returns for accounting periods beginning between 1
See MoreHong Kong: Finance Secretary of SARS presents the Budget for 2018/19
On 28 February 2018, the Financial Secretary of the Hong Kong Special Administrative Region, Mr. Paul Chan Mo-po presented the Budget proposal for the country’s tax year beginning 1 April 2018. Major proposals with respect to tax and business
See MoreMalaysia: MIRB updates the form require to collect information for TP transactions
The Malaysian tax office (MIRB) has recently updated the form used by the tax authority to gather information from certain taxpayers in connection with their cross-border transactions to conduct a transfer pricing risk assessment. Certain taxpayers
See MoreIndia: CBDT signs seven more unilateral APAs
On 1 March 2018, the Ministry of Finance issued a press release announcing that Central Board of Direct Taxes (CBDT) had signed seven further Advance Pricing Agreements (APAs) in February 2018. All seven are unilateral APAs covering the
See MoreSingapore: The excise duties imposed on all tobacco products increased by 10%
On 19 February 2018, the Budget for 2018 was presented to Parliament by the Finance Minister. The Finance Minister, Heng Swee Keat, earlier the same day during the nation’s annual Budget speech announced that the Government will impose a 10%
See MoreSingapore: Published Country-by-Country Reporting regulations
The Government of Singapore published Country-by-Country Reporting in the Singapore Government Gazette the “Income Tax Regulations 2018” on 5 February under the Income Tax Act (ITA). Country-by-Country reporting application and
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