India: CBDT extends deadline for the dispute resolution scheme
The Central Board of Direct Taxes (CBDT) has issued a Notification (No. 124/2016 of 29 December 2016) in order to extend the deadline for the Direct Tax Dispute Resolution Scheme, 2016 to 31 January 2017. The Dispute Resolution Scheme, 2016 was
See MoreAustralia releases Q&A of CbC reporting
The Australian Taxation Office (ATO) released a guidance in the form of questions and answers (Q&As) in respect of compliance with country-by-country (CbC) reporting requirements. The guidance reflects the transitional administrative practice of
See MoreTIEA between Denmark and Vanuatu enters into force
The Exchange of Information Agreement regarding tax matters (TIEA) between Denmark and Vanuatu has been entered into force on 9 September 2016. The agreement generally applies from 9 September 2016 for criminal tax matters and from 1 January 2017
See MoreIndia: CBDT Publishes draft guidelines for determination of the POEM
The Central Board of Direct Taxes (CBDT) on 24 January 2017, has issued the guiding principles to be followed for determination of the place of effective management of a company (POEM). The concept of PoEM for deciding the residential status of a
See MoreItaly-the protocol to treaty with Philippines approved
The protocol to the Income Tax Treaty between Italy and Philippines of 1980 was approved by the Italian government on 12 January 2017. The protocol was signed on 9 December 2013. According to the protocol, article 2 of the treaty would be modified
See MoreKorea (Rep.) -Competent authority agreement on automatic exchange of information with Hong Kong signed
Korea (Rep.) has signed the Competent Authority Agreement on Automatic Exchange of Information with Hong Kong on 23 January 2017. The agreement stipulated details about the types of information that will be exchanged and the timing of the exchange
See MorePanama approves TIEA with Japan
On 23 January 2017, the National Assembly of Panama approved the Tax Information Exchange Agreement (TIEA) with Japan. Furthermore, On August 25, the Government of Japan and the Government of the Republic of Panama signed the Exchange of Information
See MorePanama approves DTA with Vietnam
On 23 January 2017, the National Assembly of Panama approved the double tax agreement (DTA) with Vietnam for the avoidance of double taxation and the prevention of fiscal evasion with respect to taxes on
See MoreMalaysia: IRBM issues rules on country-by-country reporting rules (CbCR Rules)
The Inland Revenue Board of Malaysia issued the income tax (Country-by-Country Reporting) rules (“CbCR Rules”) on 23 December 2016 which came into effect on 1 January 2017. The CbC rules apply to Malaysian-parented multinational corporate groups
See MoreMalaysia: Penalty for failure to furnish country-by-country report (CbCR)
The Finance Act 2016, which was gazetted on 16 January 2017, introduced penalty provision for failure to furnish country-by-country report. A new Section 112A of the Income Tax Act 1967 is introduced to address the implications on person who fails
See MoreMalaysia: Corporate tax proposals under the finance act 2016
The Finance Act 2016, which was gazetted on 16 January 2017, introduces new corporate tax proposals to the Malaysian Income Tax Act (MITA). The highlighted area of the proposals is as given below; Special classes of income are subject to withholding
See MoreIndia: Approves amendment in modified special incentive package Scheme
On 18 January 2017, the Indian Union Cabinet has given its approval for amendment in the Modified Special Incentive Package Scheme (M-SIPS) to further incentivize investments in Electronic Sector and moving towards the goal of ‘Net Zero imports’
See MoreMalaysia: IRBM issues rules on automatic exchange of financial account information
Inland Revenue Board of Malaysia (IRBM) issued rules on automatic exchange of financial account information on 23 December 2016. The several legislations were introduced on that date including the Income Tax (Multilateral Competent Authority
See MorePakistan: Introduces an incentive scheme for industrial and trade sectors under no question on source of investment
The government has agreed on a new incentive scheme for industrial and trade sectors under which tax authorities will not question the source of investment, industry sources said on 22 January 2017. Sources in Federal Board of Revenue (FBR) also
See MoreVietnam approves protocol to a treaty between India and Vietnam
On 17 January 2017, through a press release published by the Vietnamese government, Vietnam has approved the amending protocol to a treaty between India and Vietnam. The treaty (India-Vietnam) was signed on 3 September 2016 for the avoidance of
See MoreIndia: Loss making company couldn’t be excluded from comparable list if it satisfies comparability analysis
The Ahmedabad Bench of Income-tax Appellate Tribunal in case of: Erhardt+Leimer (India) Private Limited v. ACIT (ITA Nos. 3298/Ahd/2011 & 2880/Ahd/2012) held that consistent loss-making companies cannot be rejected as comparable unless the
See MoreIndia: Foreign tax credit allowed on the basis of gross receipts
The Ahmedabad Bench of the Income-tax Tribunal (the Tribunal) in the case of Elitecore Technologies Private Limited, held that the Foreign Tax Credit (FTC) is eligible on ‘income’ and not on ‘gross receipts’. However, based on unusual facts
See MoreMalaysia: Finance Act 2017 enacted
The Finance Bill 2016 was enacted as Finance Act 2017 on 16 January 2017. The enacted Finance Act 2017 reduces the corporate tax for the year of assessment 2017 and 2018. The reduced tax rate will be between 1 and 4 percentage points for companies
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