India:Transfer pricing method applies uniformly to all international transactions
The Delhi High Court, in the case of: Magneti Marelli Powertrain India Pvt. Ltd. v. DCIT (ITA 350/2014), held that taxpayer’s contractual obligation to make a payment as per business and commercial requirements and arrangements cannot ipso facto
See MoreKazakhstan: Draft law introducing tax amendments adopted
The Ministry of Economy has announced on 17th November 2016 that the Senate had adopted a draft law (draft Law No. 26-VI; in Russian) introducing changes to the tax legislation. This draft law is sent to the President for signing and contains the
See MoreJapan: Consumption tax rate increase postponed
The Diet passed the bills postponing the consumption tax rate increase and other related measures. The bills were submitted to the extraordinary session of the Diet as a consequence of an announcement by the Prime Minister on 1 June 2016 that the
See MoreChina Proposes FTA with Russia and others
China's Deputy Minister of Commerce has proposed that the member countries of the Shanghai Cooperation Organization (SCO) – China, Kazakhstan, Kyrgyzstan, Russia, Tajikistan, and Uzbekistan should establish a free trade agreement (FTA). At the
See MoreCyprus and India signed an income tax treaty
Cyprus has signed an income tax treaty with India for the avoidance of double taxation and the prevention of fiscal evasion with respect to taxes on income. The treaty was signed on 18 November 2016. The new treaty will be replaced by the existing
See MoreIndia and Korea DTA will become effective from 2017
The India and South Korea double tax avoidance agreement will become effective from January 1,
See MoreProtocol to a treaty between India and Singapore signed
The Indian Government signed its new DTA Protocol with Singapore and entered into force on October
See MorePakistan: President enacts Companies Ordinance 2016
The President approved the Companies Ordinance 2016 on 11 November 2016, which replaces the Companies Ordinance 1984. The main points of the new company’s ordinance are set out below: –Registration and operations of companies in Pakistan have
See MoreFinland: Government submitted a bill to parliament for ratification of Finland- Sri Lanka DTA (2016)
The Finnish government submitted a bill to parliament on 10 November 2016 for ratification of the Finland- Sri Lanka Income Tax Treaty (2016), signed on 6 October 2016 in Colombo. The new treaty will be replaced by the existing Income and Capital
See MoreSingapore-New reporting requirement of related party transactions
The Inland Revenue Authority of Singapore (IRAS) updated the transfer pricing administration information on its website regarding the reporting of related-party transactions (RPTs) on 3 November 2016. According to the new requirements a company must
See MoreVietnam: Publishes the draft decree on transfer pricing
The final draft transfer pricing (TP) decree was released on 3 October 2016 by the Ministry of Finance, following Resolution No. 19-2016/NQ-CP dated 28 April 2016. The decree aims to replace the existing TP regulations, Circular 66/2010/TT-BTC, and
See MoreSri Lanka: Budget proposal 2017
On 10 November 2016, The Budget 2017 was presented to Parliament by the Minister of Finance Ravi Karunanayake. The main measures concerning corporate taxation are summarized below. Unless stated otherwise, the changes will take effect from 1 April
See MoreKazakhstan: Customs duty rate for exported bitumen lowered
The State Legal Database has published an Order No.441 of Ministry of Economy on 4th November 2016 in Russian language, which reduces the customs duty rate from $60 per ton to $15 per ton for exported bitumen. Additionally, exported bitumen is
See MoreDTA between Chile and China (People’s Rep.) enters into force
The Income Tax Treaty (2015) between Chile and People's Republic of China has been entered into force on 8th August 2016 and it generally applies from 1st January
See MoreIndian subsidiary represented by its managing director constitutes a fixed place PE in India
Recently, the Chennai Bench of the Income Tax Appellate Tribunal (the Tribunal) in the case of: Carpi Tech SA v. ADIT (ITA No 1742/Mds/2011), held that the amount received by the taxpayer pursuant to NHPC project was taxable in India since the
See MoreFinland: Government submitted a bill to parliament for ratification of Finland- Turkmenistan DTA (2015)
The Finnish government submitted a bill to parliament on 20 October 2016 for ratification of the Finland - Turkmenistan Income Tax Treaty (2015), signed on 12 December 2015 in Ashgabat. Details of the treaty will be reported
See MoreIsrael: Draft Budget Plan 2017/2018 presented
The draft budget plan for the year 2017/2018 has been presented on 31st October 2016 by the Finance Ministry. The Draft offers a decrease in the corporate income tax rate from 25% to 24% in 2017 and 23% in
See MoreMalaysia: Government plans to reduce corporate tax rate in Budget 2017
The Budget for 2017 proposed to reduce the corporate tax for the year of assessment 2017 and 2018. As per the proposal, the reduce tax rate will be between 1 and 4 percentage points for companies with significant increase in taxable income for year
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