Qatar PE rules: On 11 December 2019, Qatar introduced new Income Tax Law No. 24 of 2018, effective from 12 December 2019. The new Law provides additional guidance on permanent establishments (PEs) rule.
Computation of taxable income: With effect from 12 December 2019, the Law established rules to introduce list of non-deductible expenses. Also, this Law introduced new tax depreciation rates prescribing the straight-line method.
Treatment of losses-Carry forward: According to new Law, tax losses may be carried forward for 5 years instead of 3 years.
Thin capitalization rules: The new Law introduced debt-to-equity ratio in case of the deduction of interest on related-party loans.
Taxation of capital gains: The Law specified that capital gains tax must be paid within 30 days.
Withholding tax due: The new regulations also highlighted the scope of withholding tax payment regarding services with some conditions.
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Argentina Main corporate tax rates: On 23 December 2019, Argentina published Law 27541 and stated that the reduction in corporate income tax rate from 30% to 25% will apply from 1 January 2021 instead of 1 January 2020.
Withholding rates on dividends: Under the Law, the increase from 7% to 13% in dividend withholding tax will apply from 1 January 2021 instead of 1 January 2020.
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CFC rules: On 9 December 2019, the Executive Power published Executive Branch Decree, which includes provisions regarding the application of CFC rules.
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Algeria Incentives on industry/manufacturing: The Finance Law for 2020 includes tax incentives like profit tax for start-ups corporations and for new high technologies, creating economic zones for providing tax incentives and eliminating the 51%/49% rule for foreign investment in Algeria, particularly for non-strategic sector.
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Greece Main corporate tax rates: On 6 December 2019, Greek Parliament approved tax reform bill. The Bill proposed to reduce the corporate income tax rate from 28% to 24% for all legal entities for the fiscal year 2019 and thereafter.
Withholding rates on dividends: The bill also proposed to reduce the dividend withholding tax rate from 10% to 5% as from 1 January 2020.
Participation relief for capital gains: The bill proposed that as from 1 July 2020, capital gains derived by a Greek resident corporation from the separation of qualified participation will be exempted from corporate tax rate.
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Nigeria Reduced rate:  On 28 November 2019, the House of Representatives passed the Finance Bill 2019, which proposed a lower 20% corporate income tax rate (CIT) applies for companies with turnover between NGN25 million and NGN100 million. However, businesses with a turnover below NGN25million are to be exempted from CIT rate.
Incentives: The bill proposed that extra dividend other than profits are exempted from tax and franked investment income only to un-taxed distributions and allowing a 2% bonus tax payable to medium-sized companies and 1% bonus to large companies for the early payment of companies income tax.
Thin capitalization rules: The bill proposed to introduce thin-capitalization requirements of an interest deduction is equivalent to 30% of EBITDA for loans received from non-resident associated parties, with any additional interest expense allowed to be carried forward until five years.
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Bulgaria CFC rules: On 6 December 2019, Law on Amendments to the Corporate Income Tax Act was published. Accordingly, as from 1 January 2020, this Law amends controlled foreign company (CFC) rules and specifies the criteria for determining the persons to whom these rules apply.
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Ireland Treatment of losses: On 5 December 2019, the Revenue published guidance on the treatment of losses for Capital Gains Tax. Accordingly, the guide illustrates of how relief for allowable losses is given for CGT purposes.
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India Main corporate tax rates: On 5 December 2019, the upper house of parliament passed the Taxation Laws (Amendment) Bill, 2019, which repeals The Taxation Laws (Amendment) Ordinance, 2019. The bill also amends both the Income Tax Act 1961 and the Finance (No 2) Act 2019. The bill proposed to reduce the corporate tax rate 22% from 30% without incentives.
Reduced rate: The Bill also proposed a 15% rate for the new domestic manufacturing companies, as long as they do not claim certain deductions. The new domestic manufacturing companies must be set up and registered after 30 September 2019 and start manufacturing before 1 April 2023.
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ColombiaWithholding rates on dividends: On 3 December 2019, the Colombia Congress approved new tax reform bill 2019 in first debate, which proposed to increase the dividends tax rate from 7.5% to 10% applicable to foreign nonresidents.
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Ecuador Thin capitalization rules: On 14 December 2019, the President made objections on the second tax reform bill approved by the National Assembly. Accordingly, he proposed to limit the application of the thin-capitalization rules to intercompany loans. Accordingly, threshold would be at 300% of the entity’s equity for bank.
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Incentives on small business: On 26 November 2019, the Tax Policy Committee published a Resolution, which establishes new rules for the reduction benefit of 3% point in the income tax rate for micro and small enterprises.
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LithuaniaMain corporate tax rates: On 18 December 2019, Parliament passed higher corporate tax of 20% applicable for banks with profit exceeds 2 million euros.
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ThailandWithholding rates on interests: On 6 December 2019, Thailand has published a Ministerial Regulation regarding withholding tax on interest payments that required deducting 15% WHT.
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MexicoPE rules: On 9 December 2019, Mexico has published a Decree in the Official Gazette to implement the Tax Reform for 2020. The Reform extended the existing definition of permanent establishment rule.
CFC rules: The reform also changed the criteria for the application of CFC rules. The Mexican taxpayer will be subject to the CFC provisions that must control the foreign entity deemed to exist if the resident owns more than 50% of the votes or value of the investment or has a right to more than 50% of the dividends or assets or has more than 50% of the combined assets and profits of the entity.
GAAR: The tax reform introduced GAAR, through which the Mexican tax authorities will be re-characterize or disregard a transaction for tax purposes, if the transaction lacked a business purpose.
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RussiaCFC rules: On 18 November 2019, the Federal Tax Service published latest controlled foreign company notification form, which will apply from 1 January 2020.
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IndonesiaIncentives on industry/manufacturing: On 12 November 2019, Government issued Regulation which entered into force on 13 December 2019. The Regulation expanded the tax incentive program in industrial and bonded zones, new and renewable energy sector.
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DenmarkTaxability of other income-Royalties: On 28 October 2019, the Eastern High Court of Denmark in the case of: Denmark vs Adecco; Case No SKM2019.537.OLR of 4 July 2019, held that a Danish loss-making company could not deduct royalties paid to its Swiss parent for the use of marketing intangibles.
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NetherlandsMain corporate tax rates: On 17 December 2019, the Senate approved the 2020 Tax Plan. Under the plan, the corporate income tax rate on income up to EUR200,000 will reduce from 19% to 16.5% in 2020, followed by a further reduction to 15% in 2021. The income tax rate for income more than EUR200,000 will remain unchanged (25% rate), but this rate will be reduced to 21.7% in 2021.
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