Singapore-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
See MoreChina-Rules on advance pricing agreements updated
The State Administration of Taxation of China issued an announcement updating the rules on advance pricing agreements (APAs) (SAT Gong Gao No. 64) on 11 October 2016. The announcement seeks to improve APA management and implement the tax treaties
See MoreAustralia: Draft taxation ruling on timing for PE
On 12 October 2016, the Australian Taxation Office (ATO) released for comment Draft Taxation Ruling TR 2016/D2 that provides guidance on applying the participation test in Subdivision 768-A when working out whether an equity distribution received by
See MoreSingapore: Publishes Guidance on CbC Reporting
The Inland Revenue Authority of Singapore (IRAS) has published detailed guidance on the implementation of a new country-by-country (CbC) reporting requirement in the territory on 10 October 2016, which sets out entities are obliged to report and
See MoreHong Kong: The Inland Revenue Department clarifies the guidance on corporate treasury centre rules
The Inland Revenue Department issued the Departmental Interpretation and Practice Notes No. 52 (“Taxation of Corporate Treasury Activity”) which sets out the Department’s interpretation and practice in relation to the relevant provisions in
See MoreVietnam: Publishes Circular on tax incentives
The Ministry of Finance (MoF) on 17 June 2016, issued Circular No. 83/2016/TT-BTC which provided guidance on the implementation of investment tax incentives with regard to corporate income tax, import tax and non-agricultural land use tax. The key
See MoreChina: New changes of TP regulations
SAT Bulletin No. 42 published on July 13, 2016 has replaced the existing transfer pricing documentation regulations in Circular Guoshuifa No. 2, known as Circular 2. As per Bulletin 42, two parties will be considered related if they have “other
See MoreG20 leaders comment on tax policy
The final communiqué from the G20 summit held in Hangzhou, China on 4 and 5 September 2016 began by noting that although the global economy is recovering from the crisis growth is still relatively weak. New sources for growth are emerging but
See MoreNew Zealand: Implementation of BEPS Action 2-hybrid mismatch
The government of New Zealand released a consultative discussion document on 6 September 2016 containing proposals for addressing hybrid mismatch arrangements. The document proposes that New Zealand adopts the 2015 OECD recommendations on hybrid
See MoreIsrael: CbC reporting, transfer pricing documentation in budget plan
The Ministry of Finance’s budget plan for 2017-2018 has been approved by the Israeli government on 12th August 2016 that includes tax legislative measures. This budget plan covers: CbC reporting requirement: General rule: The Israeli budget plan
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