Indonesia: MoF issues restrictions on new foreign tax credit rules
The Minister of Finance (MoF) of Indonesia published a regulation No. 192/PMK.03/2018 regarding the implementation of tax credits on overseas income. PMK-192 is more comprehensive than the previous regulation regarding foreign tax credits (FTC).
See MoreIndia: CBDT publishes new deadline for CbC Report Local Filing for U.S. MNEs
On 8 April 2019, the Central Board of Direct Taxes(CBDT) has issued Circular 7/2019 regarding the constituent entities of U.S. MNEs are required to submit Country-by-Country (CbC) reports in India by 30 April 2019. The circular notes that
See MoreAustralia issues draft ruling on thin capitalization
On 5 April 2019, the Australian Taxation Office (ATO) released a draft ruling TR 2019/D2 with respect to the requirements for the application of the arm’s-length debt test (ALDT) in the thin capitalization rules. The draft ruling proposes that
See MoreThailand launches tax amnesty plan for SME sector
The Revenue Department of Thailand announced an opportunity for SMEs to re-submit correct tax returns without penalty and surcharge, that covers outstanding corporate income tax, value added tax, specific business tax, withholding tax, and stamp
See MoreAustralia: Federal Budget 2019-20
On 2 April 2019, the Australian Government announced its 2019-20 Budget. The Government is lowering taxes for working Australians and backing small and medium‑size business, while ensuring all taxpayers, including big business and multinationals,
See MoreThailand repeals tax incentives under ROH, IHQ and ITC regime
On 26 March 2019, the Thai Cabinet approved three Royal Decrees cancelling all tax incentives provided under the Regional operating headquarters (2010) regime (ROH), International headquarters regime (including Treasury Centres) (IHQ),
See MoreChina approves new foreign investment law
On 15 March 2019, the National People’s Congress of China has approved the Foreign Investment Law. According to the Foreign Investment Law Chinese subsidiaries of foreign parents will be treated in the same manner as Chinese-owned
See MoreJapan: Parliament enacts tax reform plans for 2019
On 27 March 2019, Japan's parliament approved the legislation for the government's tax reform proposals for 2019. Some of the main measures are following: Tax incentive: As from 1 April 2019, the tax credit rates will be revised to enhance
See MoreSri Lanka proposes Budget for 2019
On 5 March 2019 Sri Lanka’s Government proposed its National Budget 2019 to the Parliament. The Budget includes following tax measures: -Income tax exemption for interest income accrued to a resident on sovereign bonds in foreign currency, as
See MoreIndia and USA sign inter-governmental agreement for exchange of CbC reports
On 27 March 2019, India and the US signed an Inter-Governmental Agreement for exchange of Country-by-Country (CbC) reports of multinational companies regarding income allocation and taxes paid to help check cross-border tax evasion. This
See MoreHong Kong: IRD extends Country by Country (CbC) reporting notification
On 21 March 2019, the Inland Revenue Department (IRD) published an announcement of extending CbC notification in respect of the accounting period beginning 1 January 2018. Under this, the notification deadline for accounting period beginning 1
See MoreIndia: ITAT ruled that the income which is deemed to accrue or arise in India must have a territorial nexus
Recently, the Mumbai Bench of the Income-tax Appellate Tribunal (ITAT) in the case of: Fox International Channel Asia Pacific Ltd v. DCIT (ITA No.1947/Mum/2015) regarding the taxability of agency commission relating to the services rendered outside
See MoreIndia: ITAT decision on criteria for selecting transfer pricing comparable companies
The Kolkata Bench of the Income Tax Appellate Tribunal (ITAT) in the case of: Philips Medical Systems (P.) Ltd. v. ITO, held that an entity engaged in both manufacturing and trading activities cannot be a comparable company for benchmarking the
See MoreAustralia: New guidance related to inbound distribution arrangements
On 13 March 2019, the Australian Taxation Office (ATO) released a PCG 2019/1 for all multinational enterprises (MNEs) with distribution operations in Australia. This Guideline outlines compliance approach to the transfer pricing
See MorePakistan approves the Finance Supplementary (Second Amendment) Bill, 2019
On 6 March 2019, the National Assembly has approved the Finance Supplementary (Second Amendment) Bill, 2019 aimed at amending tax laws. The major changes introduced to income tax laws are as follow: -For nonbanking sectors, the super tax is
See MoreChina: New rules and requirements for tax compliance
Recently promulgated Chinese tax regulations include following changes affecting corporate income tax: Increase to the unit value of fixed assets eligible for the “one-off deduction method” to RMB 5 million;Increase to the deduction limit
See MoreChina aims to reduce taxes in 2019
On 5 March 2019, Mr. Li Keqiang, the Premier declared that the Chinese government is planning to reduce CNT 2 trillion in taxes and fees for companies during 2019. He also included that the government is planning to reduce Value Added Tax (VAT)
See MoreTaiwan: NTBNA publishes Guidance on Submission of TP documentation
On 26 February 2019, National Taxation Bureau of the Northern Area (NTBNA), Ministry of Finance of Taiwan has published guidance on the submission of the Master file and Country-by-Country report by MNEs. Here are the key points as follows: The
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