Pakistan: Foreign tax registration documents mandatory for non-resident companies
The Federal Board of Revenue (FBR) has proposed to make it mandatory for non-resident companies with or without a permanent establishment (PE) in Pakistan to be registered for tax purposes and to provide their company and business details (including
See MoreIndia: The Tribunal held that, no transfer pricing adjustment of AMP expenses
The Mumbai Bench of the Income-tax Appellate Tribunal in the case of: L’Oreal India Pvt. Ltd. v. DCIT , held that the tax officer must prove that the taxpayer’s real intention in incurring an advertising, marketing, and promotion (AMP)
See MoreIndia: Proposes amendments to Finance Bill 2016
The Finance Bill, 2016 (the Bill) was introduced by the Finance Minister on 29 February 2016 in the Lok Sabha. On 5 May 2016, the amendments to the Bill have been proposed by notice of amendments. The Bill has proposes following amendments: -The
See MoreAustralia: Tax incentives for early stage innovation investors
On 6 May 2016, the Tax Laws Amendment Bill 2016 received Royal Assent, enacting additional income tax incentives for new investments in Australian early-stage innovation companies (ESICs). From 1 July 2016, investment in a qualifying early stage
See MoreATO published a Practice Statement for TP penalties in transition period
The Australian Taxation Office published a Practice Statement Law Administration 2016/2 (PS LA 2016/2) to deal with the application of transfer pricing penalties during the transition period between 1 July 2004 and 28 June 2013. During that period,
See MoreIndia: APA for earlier year may apply, determining “tested party”
Recently, the Delhi Bench of the Income-tax Appellate Tribunal (the Tribunal) in case of: Ranbaxy Laboratories Ltd. v. ACIT (ITA No. 196/Del/2013), held that overseas Associated Enterprises (AEs) being least complex entities in the transaction,
See MoreAustralia: Amended the Transfer Pricing Rules as per 2015 OECD Transfer Pricing Recommendations
Australia's transfer pricing legislation currently specifies that it be interpreted to achieve consistency with the OECD transfer pricing guidelines as last updated in 2010. The OECD's final report on Action Items 8-10 of the G20/OECD BEPS Action
See MoreAustralia: Reducing the corporate income tax rate
On 3 May 2016, the government of Australia announced in the 2016–17 Budget that it will reduce the corporate tax rate progressively from 30 per cent to 25 per cent. Currently, there is a small business corporate tax rate which is less than the
See MoreVietnam: Corporate tax incentives for regular investment activities
The Ministry of Finance on 7 April 2016, published Official Letter No. 4769/BTC-TCT which providing criteria on tax incentives for regular investment activities. As per this guidance, “regular investment activities” is defined as regular
See MoreIndia: Central Board of Direct Taxes issues draft rules concerning foreign tax credit
India’s Central Board of Direct Taxes (CBDT) issued the draft rules: F. No. 142/24/2015-TPL, concerning the foreign tax credit and specifying the procedure for granting relief for income taxes paid in another country of foreign territory. As per
See MorePlatform for Collaboration on Tax set up by OECD, IMF, UN and World Bank
On 19 April 2016 the OECD, IMF, World Bank and UN announced the creation of a Platform for Collaboration on Tax. The Platform will intensify cooperation between these bodies as well as hosting regular consultations on the design and implementation
See MoreKazakhstan: MoJ approves plans to consolidate tax code and customs code
The Ministry of Justice has approved plans on 5th April 2016 that are aimed at consolidating the Tax Code and the Customs Code into one single code. Note that, Kazakhstan became a member of the WTO on 30 November 2015. These plans will be effective
See MoreIndia: Bench marking the arm’s length interest rate on related-party debt
The Mumbai Bench of the Income-tax Appellate Tribunal held in the case of India Debt Management Pvt. Ltd. v. DCIT [IT(TP)A No. 7518/Mum/2014, held that the selection of tested party shall be done with reference to the entity which has undertaken
See MoreIndia: Factors to be used in selecting comparables
The Bangalore Bench of the Income-tax Appellate Tribunal recently provided judgment in the case of ACIT v. McAfee Software (India) Pvt Ltd, on factors such as functional comparability that are to be used in transfer pricing reports and
See MoreKazakhstan: Capital gains resulting from transfer to charter capital of legal entity are exempted
The State Revenue Committee published a press release on 1st April 2016 describing the amendments to the taxation of property transactions conducted by individuals. According to the release, the amendments were introduced by Law No. 412-V of 18
See MoreMalaysia: IRB is planning to introduce a Country-by-Country (CbC) reporting requirement
The Malaysian Inland Revenue Board announced plans to introduce a Country-by-Country reporting requirement and to update current local transfer pricing documentation requirements to include the Master File and Local File concepts, in line with
See MoreJapan approves tax reforms for 2016
The parliament (National Diet) on 29 March 2016 passed the tax reform for 2016. The main changes are set out below: Corporate income tax: The main corporation tax rate is to be reduced to 23.4% from 23.9% for taxable years beginning on or after 1
See MoreSingapore: Finance Minister presents the 2016 budget to Parliament
The Budget for 2016 was presented to Parliament by the Finance Minister on 24 March 2016. A summary of the Budget with regard to corporate taxation is set out below: Tax incentives: -Under the Productivity and Innovation (PIC) Scheme the cash
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