Australia Sanctions for tax evasion: On 18 December 2017, the Australian Taxation Office was published a draft law companion guideline (LCG) 2017/D7 on Diverted profits tax (DPT) for public consultation. The draft Guideline addresses Schedule 1 to the Treasury Laws Amendment Act 2017 which introduced 40% Diverted profits tax rate on artificially diverted profits from Australia by significant global entities.
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Belgium Main corporate tax rate: On 22 December 2017, the Belgian parliament enacted the major corporate tax reform for 2018. Accordingly, 1 January 2018, the corporate tax rate is reduced from 33.99% to 29.58% (crisis contribution being reduced from 3% to 2% is included).
Reduced rate: From 1 January 2018, small and medium-sized enterprises (SMEs) will benefit from a 20.4% rate (crisis contribution of 2% included) on the first bracket of €100,000 of net taxable income.
Incentives for small business: From 1 January 2018, the investment deduction for SMEs will be increased from 8% to 20% for investments made in 2018 and 2019 and linked to assessment years 2019 and 2020.
Sanctions for non-compliance: From 2018, the late payment interest would amount to minimum 4% and maximum 10%. The default interest rate would be 2% lower than late payment interest.
Sanctions for tax evasion: From 1 January 2018, in the case of non-filing or incorrect-declaration of corporate tax returns, penalty will Increases including a rise in the deemed taxable lump sum amount from EUR 19,000 to EUR 34,000 for 2018-2019 and increased to EUR 40,000 from 2020, as well as a further increase of 25% to 200% in the case of subsequent infringements.
Thin capitalization rules: The current thin capitalisation rules are to be generally replaced by an interest restriction from 2020. A restriction on deductible interest is to be introduced in line with the EU anti-tax avoidance directive (ATAD).  There will be a limit on tax deductible interest of 30% of earnings before tax, interest, depreciation and amortisation (EBITDA). Companies will be able to carry forward the disallowed interest to future periods. The thin capitalization rules will no longer apply to these companies but the rules are retained for groups under the EUR 3 million threshold. The thin capitalization rules will also continue to apply in the case of payments to low or no tax jurisdictions.
CFC rule: The CFC rule will enter into force as from 1 January 2019. Based on the new CFC rules certain non-distributed income of a CFC would become taxable in Belgium in the hands of the Belgian controlling taxpayer. A CFC is a lowly taxed foreign company (or a foreign PE) of which a Belgian taxpayer (alone or together with its associated enterprises) holds directly or indirectly more than 50% of the voting rights or the capital or is entitled to receive more than 50% of the profits of that entity. In addition, the CFC is either not subject to income tax under the applicable rules of its residence State or is subject to income tax which is less than half of the corporate income tax of the CFC computed based on Belgian rules.
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Chile Low tax jurisdictions: Tax authority published a Resolution No. 124 of 19 December 2017 regarding the list of jurisdictions that are considered to have a preferential tax regime or zero or low taxation. The list contains 153 jurisdictions. It aims to provide certainty and facilitate the correct voluntary tax compliance of taxpayers, contemplating additionally the possibility of knowing and receiving the doubts, observations and recommendations of the different stakeholders.
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Argentina Main corporate tax rate: Argentina legislated a complete tax reform bill through publication in the Official Gazette on 29 December 2017. Accordingly, the corporate tax rate would be gradually reduced from 35% to 30% in 2019 and 2020, and 25% in 2021 and ongoing. The Law is generally effective 1 January 2018.
Withholding tax on Dividend: Argentina legislated a complete tax reform bill through publication in the Official Gazette on 29 December 2017. Accordingly, A 7% dividend withholding tax rates was established for profits accrued during fiscal years starting January 1, 2018 to December 31, 2019, and 13% for profits accrued in fiscal years starting 1 January 2020 and onward. The Law is generally effective 1 January 2018.
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France Surcharge: The French Constitutional Court declared its judgment on the recently approved temporary surcharge on large companies on the 29 November 2017. The surcharge is levied at a rate of 15% for companies with gross revenue exceeding EUR 1 billion, with an additional 15% surcharge for companies with gross revenue exceeding EUR 3 billion.
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Iceland Taxation of capital gains: On 14 December 2017, the Ministry of finance published the budget proposals for 2018. Accordingly, from 2018, the financial income (capital gains) tax rate will rise from 20% to 22%, whereupon the tax base will be reviewed.
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Italy PE rules: On 30 November 2017, the Senate approved the draft Budget Law for 2018.  The draft budget law includes a broader definition of permanent establishment (PE) in order to make it fully consistent with that proposed by the OECD in the BEPS Action 7 Final Report. The amendment extends the agency PE definition and makes the ‘negative’ list conditional on the taxpayer proving the preparatory or auxiliary nature of the activities. It also includes the ‘anti-fragmentation rule’. Moreover, the amendment introduces an additional definition of a fixed-place PE.
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Japan PE rules: Japan approved tax reform plan for 2018 on 14 December 2017. According to the plan, the permanent establishment definition under the Japanese domestic tax law will be amended. The amendments basically follow the recommendations by the Organization for Economic Co-operation and Development in the Base Erosion and Profit Shifting Action 7 final report. The bill will be submitted to Parliament and is expected to enter into force by the end of March 2018.
Incentives: Japan approved tax reform plan for 2018 on 14 December 2017. Under the tax reform package, the large companies will be eligible for a tax credit of up to 20% of increased salary payments, if they hike pay by 3% or more, and small and medium-sized companies will qualify for credit of up to 25% if they increase wages by more than 2.5%. The bill will be submitted to Parliament and is expected to enter into force by the end of March 2018.
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Korea, Rep Of Main corporate tax rate: The Government passed the 2018 budget on 6 December 2017. Under the budget, the threshold of the new highest corporate income tax rate of 25% (previously 22%) has been increased from KRW 200 billion to KRW 300 billion. A 10% local income tax surcharge is also imposed on the current and proposed corporate income tax rates.
Incentives: The Budget for 2018 also includes a reduction in the R&D tax credit for large companies from 3% to 2%, with an increase in the credit for smaller companies from a range of 20% to 30% to a range of 25% to 40%.
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Netherlands Incentives: The Ministry of Finance provides an overview of the most important tax changes as of 1 January 2018, which were approved by parliament on 19 December 2017.  Accordingly, the effective rate of the innovation (IP) box regime income tax will be increased from 5% to 7% by January 1, 2018.
Withholding tax on Dividend: The Ministry of Finance provides an overview of the most important tax changes as of 1 January 2018, which were approved by parliament on 19th December 2017.  Dividend withholding tax liability will be extended to qualifying holdings in cooperative holding companies (i.e. membership rights that grant an entitlement to at least 5% of the annual profit or to at least 5% of the liquidation dividends) if in the previous year, their activities usually consist for 70% or more of owning shareholdings that qualify for the participation exemption (directly or indirectly) loans to affiliated companies.
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Poland Incentives: On 24 November 2017, the President signed the law regarding research and development (R&D) incentives. Accordingly from 2018, the tax deduction level will rise to 100% of eligible R&D expenditures (up from 30% – 50%, depending on type of taxpayer and category of expenditure). An increase in the deduction to 150% for eligible R&D expenses of qualifying R&D centers. Additionally, certain expenditures on protection of industrial property will become eligible R&D expenditures for large enterprises (currently only for SMEs).
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Portugal Taxation of capital gains: On 27 November 2017, Portugal’s parliament approved the 2018 Budget Law. The budget introduced an extension of capital gains taxation rules so that gains from the transfer of foreign shares or similar rights may be taxed in Portugal if more than 50% of their value is derived from immovable property situated in Portugal.
PE rules: On 27 November 2017, the Portugal’s parliament approved the 2018 Budget Law. The budget introduced new rules for permanent establishment. In order to determine the taxable income of a foreign permanent establishment (PE), taxpayers must adopt adequate and justified proportional attribution criteria in respect of losses, expenses and negative capital variations arising from transactions involving both PEs and taxpayers.
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Russia Incentives: On 20 November 2017, the Federal Tax Service (FTS) clarified the procedure for legal entities to shift to the simplified tax system from 2018. In order to switch to the simplified tax regime as from 2018, legal entities already operating under the general tax regime must comply with the income limit of EUR 1,617,981 over 9 months in 2017. In addition, the residual value of the fixed assets as of 1 January 2018 should not exceed EUR 2,156,787.
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Computation of taxable income: On 23 November 2017, the Government approved a plan to introduce a profit-based tax on the oil industry from 2019. Currently, the tax regime for the oil industry stipulates that oil companies pay the so-called mineral extraction tax (MET), which is calculated on the basis of the volumes of oil and gas extracted. The new tax regime is expected to be approved by Russia’s Parliament in the first quarter of 2018 and enter into force on 1 January 2019 although the rate has not yet been specified.
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Turkey Main corporate income tax rate:  On 5 December 2017, the draft law on various tax measures was published in the Official Gazette. As from 1 January 2018, the corporate income tax rate for all companies will be increased from 20% to 22%. The increased rate will apply for the years 2018 to 2020.
Taxation of capital gains:  The exemption from tax of capital gains derived by corporate taxpayers from the sale of immovable property held for at least 2 years will be reduced from 75% to 50%. This change will apply from 5 December 2017 (the publication date of the adopted bill in the Official Gazette).
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US Main corporate tax rate: On 22 December 2017, President Donald Trump signed the Tax Cuts and Jobs Act (TCJA). The current version of the tax plan features a 21% corporate tax rate and the removal of the corporate alternative minimum tax (AMT).
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