Chile CFC Rule: Under the Circular 30 of the tax administration from  2016, the main aspects of the CFC rules are: A controlled foreign entity exist where a Chilean resident holds, directly or indirectly, more than 50% of the shared capital, voting rights or rights over profits in the foreign entity. Furthermore, the CFC rules deem as passive income any type of income from transactions with related parties in Chile that imply a deduction for the payer and which payment is not sourced in Chile or, being sourced in Chile, are subject to a tax rate that is less than 35%.
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China Incentives: China’s tax administration issued guidance concerning implementation of the 150% “super deduction” available under the research and development (R&D) regime.
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Italy Main corporate tax rate: The budget law for 2016, has now been approved and includes reduction of corporate tax rate for 2017. The Law no. 208 of 28 December 2015 provides a reduction of the applicable corporate income tax (IRES) rate from 27.5% to 24% for financial year 2017 and onwards.
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Surtax : With effect from the tax year following the tax year ongoing on 31 December 2016, qualifying banks and financial institutions will be subject to a surtax of 3.5%.
Withholding tax: Also, the reduced withholding tax levied on dividends paid out to a company resident and subject to corporate income tax in another EU Member State or EEA Member State that allows an adequate exchange of information with Italy will be decreased from 1.375% to 1.20%.
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Israel Main corporate tax rate: The Parliament of Israel has published the Law for the Amendment of the Israeli Tax Ordinance on 5th January 2016, which reduces the standard corporate income tax rate from 26.5% to 25%. This amendment enters into force from 1stJanuary 2016 and applies to income generated after January 1, 2016 on a pro-rata basis.
Withholding tax: Under the domestic law, withholding tax rates on interest, royalties, or capital gains regarding corporations are subject to 25% from 1st January 2016.
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Norway Main corporate tax rate: The Norwegian Government has approved its 2016 Fiscal Budget on 14 December 2015. Following changes are made: The corporate income tax rate has been reduced from 27% to 25%.
Incentives on Research and development: The current limit of NOK15 million increases to NOK20 million for in-house research and development (R&D), while the cap for procured R&D increases from NOK33 million to NOK40 million under the Norwegian tax incentive scheme for R&D.
Participation exemption: The application of the participation exemption with regards to dividends received by a Norwegian company will no longer apply to the extent that the distribution has been tax deductible at the level of the distributing entity (hybrid instruments).
Special corporate rate: For companies taxed under the special petroleum tax regime and the hydro power regime, the reduction in corporate tax rate will be balanced by a corresponding increase in the special tax rates for these regimes.
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Ukraine Filling Tax return: Corporate taxpayers with annual turnover exceeding UAH 20 million are required to submit a tax return related to tax year 2015 by 9 February 2016. Corporate taxpayers with annual turnover not exceeding UAH 20 million must submit the tax return by 29 February 2016.
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Withholding taxes due: According to recent amendments to the Tax Code adopted on 24 December 2015, advance corporate income tax payments due upon distribution of dividends should be offset against the taxpayer’s outstanding corporate income tax liabilities in the same tax reporting year.
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Russia Interest rate: In Russia, recently passed important tax laws on corporate tax from 2015 onwards, accordingly, in 2016, an interest rate threshold from 75% to 125% for the Central Bank will apply in the case of debt obligations. This will increase the number of transactions for which interest will be recognized under the transfer pricing rules.
Capital Gains: A CGT must be formed for no less than 5 years and it will apply to CGTs registered after January 1, 2018.
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Ecuador Reduced rates: According to Presidential Decree issued on 30 December 2015, a single corporate income tax regime for the banana sector is established with rates that range from 0.50% to 2%.
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Colombia Statute of limitations for penalties: In a recent court decision the Tax Court ruled on determining the statute of limitations for the tax authority to impose penalties. Article 638 of the Tax Code presents the statute of limitations for imposing penalties as a result of tax filing discrepancies. The penalties may be imposed by the National Tax Authority either through an official reassessment decision or an official independent decision. The statute of limitations for issuing such official decisions is 2 years.
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Oman On 23 December 2015, the lower house of the Council of Oman has approved a number of changes to Income Tax Law. The proposed changes that are likely to apply to companies and other entities include:
Corporate Tax Rate: The corporate tax rate is expected to be increased from 12% to 15%.
The tax free threshold (standard deduction) of RO30,000 (US$78,000) is likely to be removed.
Certain companies that were not subject to income tax based on their business activities, industry sector or revenues may now be subject to tax.
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Poland Financial institutions Tax rates: Poland’s President has signed into law a Bill on the Tax on Financial Institutions which was published in the Official Journal on 15 January 2016. According to the law the tax rate will be 0.0366% of the taxable base and the tax will be charged on the total value of assets exceeding PLN 4 billion on domestic banks, branches of foreign banks, branches of credit institutions, and cooperative savings and credit institutions.
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Turkey Incentives: The Prime Minister announced an R&D Reform Package (the Package) on 14 January 2016, to increase the share of R&D activities in the Turkish economy from 1% to 3%.
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Uruguay Incentives: In Uruguay, Decree No. 325/015 of 7 December 2015 extended the period of validity of tax benefits provided for manufacturing agricultural machinery and equipment under Decree No. 220/998, According to the decree, the exemption from income tax on 90% of the net fiscal income derived from manufacturing agricultural machinery and equipment will apply further to 31 December 2017. Also, the exemption from income tax on 50% of the net fiscal income derived from manufacturing agricultural machinery and equipment applies from 1 January 2018 to 31 December 2022.
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Thailand Incentives: The Deputy Prime Minister of Thailand announced on 4 January 2016 some further tax incentives for targeted industries. According to the announcement in Thailand, double tax deductions will be provided on capital investments like the procurement of machinery, equipment, computer software, etc. made by foreign investors before 31 December 2016.
Also, for the research expenditure incurred during the period 2015 to 2019 triple tax deductions will be provided.
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Venezuela Income tax rate for Banks: The tax reform measures in Venezuela have been published in official gazette on 30th December 2015. Changes to the income tax law are effective from the beginning of January 2016. Accordingly, the income tax rate has been increased from 34% to 40% for banks and insurance companies.
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