Australia GAAR: The Tax Laws Amendment (Combating Multinational Tax Avoidance) Bill 2015 received Royal Assent on 11 December 2015. The Bill implements a new anti avoidance rule designed to counter the erosion of the Australian tax base by multinational entities using artificial or contrived arrangements to avoid the attribution of business profits to Australia through a taxable presence in Australia. This new rule will apply from 1 January 2016.
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Anti-Avoidance/Anti-Evasion rule: The Government has secured the passage of the Tax Laws Amendment (Combating Multinational Tax Avoidance) Bill, a critical piece of legislation, which will ensure major international companies operating in Australia but booking profits offshore have to pay tax in Australia, on 3 December 2015.
Penalty for non-compliance: The maximum penalty for tax avoidance and profit shifting arrangements will be doubled up to a maximum of 120% of the tax avoided for groups with A$1 billion global turnover. The Reform will be effective from 1 January 2016.
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Ukraine Main Corporate tax rate: On 10 December 2015, the Ministry of Finance published a second draft of the law amending the Tax Code. The major deviations from the first draft are the corporate tax rate is decreased to 18% from 20%. The rate will be further decreased to 17% in 2017. Also, advanced corporate income tax payments are abolished.

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Thin capitalization rules: Thin capitalization rules included in the draft Law No. 3357 of 26 October 2015.

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Hungary Bank surtax rate: According to the proposed bill of Hungary the current bank surtax rate applicable to bank assets exceeding HUF 50 billion would be reduced from 0.53% of the taxable base to 0.31% in 2016, and to further reduce it to 0.21% in 2017 and 2018. But the surtax of 0.15% applicable up to HUF 50 billion of the taxable base will be kept unchanged.
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Japan Main Corporate tax rate:  On 10 December 2015, Japan’s ruling party approved a plan to further reduce the corporate tax rate for the fiscal years 2016 and 2018. It is now proposed that the effective tax rate be reduced to 29.97% for the fiscal year 2016 and to 29.74% from the fiscal year 2018 onwards. In the tax reform plan announced late last year the headline corporate income tax rate was reduced from 34.62% (2014) to 32.11% (2015) and was to be further reduced to 31.33% in 2016.
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UK Incentives: The UK has published statistics relating to the claims made for creative industry tax relief. The statistics include data for the film tax relief, high end television tax relief and animation tax relief for periods to April 2015. In the case of high end television tax relief and animation tax relief this is the first time that statistics have been published. Some of the published figures are still provisional and may be amended at a later date.
Dividend: On 9 December 2015, HMRC published draft legislation under which the dividend tax credit (i.e. one-ninth of the dividend value) will be replaced, with effect from 6 April 2016, by a new dividend allowance in the form of a 0% tax rate on the first GBP 5,000 of dividend income per year.
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Russia CFC rules: A draft of Federal Law No. 953192-6 regarding the СFC provisions has been submitted to the lower chamber of the parliament on 14th December 2015. The СFC provisions were introduced by the Tax Code and Federal Law No. 376-FZ of 24 November 2014. The draft law is expected to be passed by the lower chamber of parliament and approved by the upper chamber. The draft law establishes that the profit/loss of a CFC may be determined based on either its financial statements or according to the rules provided by Chapter 25 of the Tax Code. However, the first option is available only if one of the following criteria is met: (i) the CFC resides in a state with which Russia has signed an international agreement on tax matters, except for states which do not ensure exchange of tax information with Russia; or (ii) An audit report of the financial statements is made and the audit report does not contain a negative conclusion.
Dividend: Dividend payments from profits that were previously taxed in Russia under the CFC rules are exempt from taxation in Russia.
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Lithuania Filling Return: On 17 November 2015, draft amendments to various tax laws were approved by the parliament which introduce a single date rule for (i) filing tax returns and (ii) payment of taxes by legal entities. Accordingly, the deadline for filing tax returns and for payment of taxes is the 15th day of the month following the end of the relevant tax period. Relevant annual tax returns must be filed in due time and final taxes must be paid by the 15th day of the reporting month. If adopted by the parliament in the final reading, the amendments will enter into force on 1 January 2016.
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China Incentives: China’s State Administration of Taxation, Ministry of Finance and the Ministry of Science and Technology jointly released Cai shui [2015] No.119 on 2 November 2015, to provide expanded scope and follow-up guidance of qualified industries and research and development (R&D) expenses eligible for the super deduction. Circular 119 defined the qualified R&D activities and covered industries that are eligible for the super deduction policies. Under the China Corporate Income Tax Laws, qualified R&D expenses could be deducted, or amortized if capitalized as intangible assets, at 150% of the actual incurred costs.
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India Residence rules: India’s Central Board of Direct Taxes (CBDT) issued draft guiding principles for determining if a company is a resident in India or has its place of effective management in India.The Finance Act, 2015, amended the provisions of section 6(3) of the Income-tax Act, 1961 to provide that a company is a resident in India for any previous year, if it is an Indian company or its place of effective management for that year is in India. For these purposes, the place of effective management means the place where key management and commercial decisions that are necessary for the conduct of the business of an entity as a whole are, in substance, made.
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Colombia GAAR: The National Tax Authority of Colombia (DIAN) in a recently published Ruling no: 25473 of 2015, update the rules on general anti-avoidance rule (GAAR) which provided under article 869 of the Tax Code. In accordance with sub-paragraph 4 of article 869 of the Tax Code, DIAN must prove no less than three of the five assumptions provided under article 869-1 of the Tax Code. Once those assumptions are proved by DIAN, the general anti-avoidance rule (GAAR) Committee may request the taxpayer to exercise his right to dispute the charges.
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Mexico Mexico publishes new Income Tax Law regulations regarding corporate taxation. The new regulations to the Income Tax Law were published in the Official Gazette on 8 October 2015. The main changes included in the regulations are:
Thin capitalization rules: For purposes of thin capitalization rules, the regulations refer to the Foreign Investment Law to define the strategic areas to which such rules will not apply. Also, the thin capitalization rules for the electrical energy sector, by excluding debts incurred in connection with the investment in infrastructure related to power generation, with application retroactive from 2014.
Filing Returns: New informative returns have to be filed by financial institutions on interest paid and on gains or losses realized on the sale of shares. For treaty application, foreign residents may prove their tax residence through residence certificates or documentation issued by the corresponding authority, proving that the tax return has been filed.
Permanent establishments:For permanent establishments, specific regulations are included on the applicable treatment of CURECA (Reimbursement Capital Account) and regarding the effect of accelerated depreciation of fixed assets in force under previous laws.
Incentives: Regarding tax incentives, rules are included in the application of risk capital investments.
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Brazil Filing return: Brazil’s tax authority recently announced following filing deadlines for companies that are required to maintain:
– Digital accounting bookkeeping (Escrituração Contábil Digital – ECD) – due by 31 May 2016 or the last business day of May.
– Accounting tax bookkeeping (Escrituração Contábil Fiscal – ECF)- is due by 30 June 2016 or the last business day of June.
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Israel Main Corporate tax rate: The Ministerial Committee on Legislation has approved the proposal of the Prime Minister and Finance Ministry on 6th December 2015 to reduce the corporate income tax rate from 26.5% to 25% with effect from 1st January 2016.
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Sri Lanka The Finance Minister of Sri Lanka has presented the national budget 2016 on 20 November 2015. The Budget includes following changes related to the corporate income tax:
Special Corporate Tax rate: 30% for betting and gaming, liquor, tobacco and banking and financial services, including insurance and leasing industry and the trading activities.
– 15% for all other sectors.
– Quoted companies to distribute minimum of 15% of distributable profits as dividends.
Surtax on Tobacco, Liquor and Casinos: Surtax at the rate of 25 percent of income tax liability.
Transfer pricing: Administration of the transfer pricing (TP) on domestic transactions will be simplified and the areas will be specified, limiting the scope. Penalty provisions will be introduced to ensure proper implementation of TP regulations.
Refund: The Budget 2016 proposes that, for a refund claim for any year of assessment commencing on or after 1 April 2016, issuance of such refund should be made within three years from the claim shown on the return; otherwise, the refund would be credited against future tax liability.
Tax incentives: A 50% tax reduction for a period of 5 years will be given to companies that set up in lagging regions of the country through a minimum investment of USD10.0 mn (excluding land and building) or 500 new employment opportunities. The period will be extended to 8 years if more than 800 jobs are created.
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 Argentina Surcharge on tax: In Argentina General Resolution 3819 was published in the Official Gazette on 17 December 2015. The Resolution abolishes the Income Tax and Net Worth Tax surcharges (Percepción) enacted by General Resolution 3450 and General Resolution 3583. This new Resolution became effective from its publication date in the Official Gazette.
Further, General Resolution 3819 establishes a new surcharge of 5% on the provision of foreign travel services when payment is made in cash and the tax will be collected by the travel agents and transport companies.
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Venezuela Main Corporate tax rate:Under the Presidential Decree No. 2.163, an amendment to the Income Tax Law (ITL) was published in the Official Gazette on 30th December 2015 which circulated on 4 January 2016. The amendment contains an increase in the corporate income tax rate from 34% to 40%.
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France Participation exemption: An amendment was adopted by the National Assembly on 2 December 2015 to abolish the neutralization within tax consolidated groups of the 5% add-back on dividends qualifying for the participation exemption. The add-back will therefore be reduced to 1% in the case of certain dividend payments.Following the amendment dividends qualifying for the participation exemption and received by a French company that is a member of the same tax consolidated group will not be fully exempt and instead the dividends will be subject to a 1% add-back. Dividends received from a subsidiary in an EU or EEA country that would qualify to be a member of a tax consolidated group if resident in France will also be subject to the 1% add back. The amendment takes effect for financial years beginning on or after 1 January 2016.
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Korea (Rep. Of) Treatment of losses: The National Assembly of Korea passed the Tax Reform Bill of 2016 on 2 December 2015. The bill was enacted on 15 December 2015 and certain Enforcement Decrees are expected to be approved by the Government in the near future.
According to the current tax law the net operating losses can be carried forward for 10 years to compensate the taxable income without any condition limitation. The tax reform bill introduces an annual deductibility limitation of 80% of taxable income.  However, companies classified as small and medium sized and certain companies specified under the Enforcement Decree of Corporate Income Tax Law (CITL ED) including companies under court receivership will fall within the 80% limitation.
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