Argentina | Dividend: In Argentina, Law 27,260, the amendment to the Income Tax Law (LIG) was publishes in the Official Gazette. According to the amendment Law 27,260 abolished the 10% withholding tax established by article 90 LIG which was applied to companies on the distribution of dividends and profits of the company. See the story in Regfollower |
Bangladesh | The Bangladesh Ministry of Finance presented the Budget measures relating to corporate taxation on June 2, 2016. The Finance Bill was passed in the parliament on 29 June 2016 (and became effective from 1 July 2016. Rates: According to the budget, the minimum tax rates will be increased, ranging from 0.6% to 1%. The 5% additional tax will also impose on public listed companies for declaring dividends of less than 15% will be withdrawn. Financial year for bank: According to the budget, the income year for subsidiaries of any banks and insurance and financial institutions must coincide with the calendar year, i.e. 1 January to 31 December. Interest on Bank: According to the budget, 5% withholding tax rate will be levied on any interest on any savings, fixed or term deposits maintained by a tax-exempt fund. Incentive on SME: According to the budget, The limit for turnover for the purpose of tax exemption for any small to medium-sized enterprises will be increased from BDT 3 million to BDT 3.6 million. See the story in Regfollower |
Romania | Incentives: The Romanian Government published an Official Gazette order approving the norms on the supplementary deduction for research and development (R&D) expenses on 13 July 2016. Under the provisions of the Tax Code, a supplementary deduction of 50% may be claimed for corporate income tax purposes in respect of R&D expenses. See the story in Regfollower |
Luxembourg | Main corporate tax: The government of Luxembourg adopted tax reform plans for the year 2017 on 13 July 2016. Accordingly, the standard corporate income tax rate will be reduced from 21% to 19% in 2017 and be further reduced to 18% in 2018. For start-up companies with a profit not exceeding EUR 25,000, the standard corporate income tax rate will become 15% from 2017. See the story in Regfollower |
Uruguay | Interest rates: The chamber of Deputies of Uruguay received for discussion the Accountability Bill on 20 June 2016. The Bill was issued by the Executive Branch. According to the Bill the current interest rate of 3% will be increased to 7% for: (a) for interest paid by financial institutions from long-term deposits made in Uruguayan persons or with indexed units of more than 1-year term. (b) For interest derived from corporate bonds or other debt instruments issued by resident entities with a period of more than 3-years. (c) For income derived from certificates of participation in financial trusts with period of more than 3 years. Similarly, the current interest rate of 5% applicable to 1-year term deposits or deposits of less than 1 year, in domestic currency without a readjustment clause will be increased to 7%. Furthermore, the current interest rate applicable to entities resident, domiciled, constituted or located jurisdictions with low or no taxation, or benefiting from a special regime of low or no taxation will be increased from 12% to 25%. See the story in Regfollower |
Slovenia | Incentive: The Financial Administration publishes the guidance on the application of research and development (R&D) tax incentives on 14 July 2016. According to the guidance, companies may claim a 100% corporate income tax base reduction for qualifying costs. See the story in Regfollower Main corporate tax: The government recently publishes a proposal for amending the Corporate Income Tax Law. According to the proposal the corporate income tax rate will be increased to 19% (currently 17%). See the story in Regfollower |
Greece | Carry forward losses: The Public Revenue Authority published Circular POL 1088 on 24 June 2016, according to article 27 of the ITC; losses incurred by any type of company may be carried forward for 5 years. See the story in Regfollower |
Namibia | Management fees: From 21 June 2016, the withholding tax rate applicable to directors’ fees paid to non-residents has become 25% in Namibia. See the story in Regfollower |
Indonesia | Incentive: The Government of Indonesia recently announced tax incentives for apparel, leather and footwear industries with the Regulation No. 9, 2016. See the story in Regfollower |
Colombia | Late payment-interest: The Financial Supervisory Authority of Colombia recently issued Administrative Regulation 0811 of 2016 about the late payment interest rate. According to the Regulation, the effective annual interest rate is 32.01% that applicable for late payment of taxes. See the story in Regfollower |
Taiwan | CFC rule: Taiwan’s Legislative Yuan amended the Income Tax Act (ITA) on 12 July 2016, and introduced the controlled foreign company (CFC) rules, incorporating some of the recommendations provided in the Organization for Economic Co-operation and Development’s final report on Action. PE rule: The amendment also provides criteria for determining a foreign company’s place of effective management. Once the foreign company’s place of effective management is deemed to be in Taiwan, the foreign company is subject to tax on its worldwide income. See the story in Regfollower |
Turkey | Incentive: The Turkish Revenue Administration has published guidelines regarding corporate income tax (CIT) incentive on 30th June 2016 for capital increase. According to that incentive, capital companies may able to deduct 50% of the interest calculated over the cash capital increases from the corporate tax base. See the story in Regfollower |
Poland | Rates: The lower chamber of the Polish Parliament approved a bill amending the Corporate Income tax Act on 22 July 2016.The changes will come into effect on 1 January 2017. Accordingly, small corporate taxpayers (gross sales reported for the previous year are less than €1.2 m) and corporate taxpayers origination business activities may benefit from a lower tax rate of 15% but the standard CIT rate is 19%. See the story in Regfollower |
Singapore | GAAR: The Inland Revenue Authority of Singapore (IRAS) issued an e-Tax Guide (the Guide) on 11 July 2016, clarifying the general anti-avoidance rule and its application. See the story in Regfollower |
India | GAAR: The Central Board of Direct Taxes (CBDT) issued Notification No. 49/2016 (the Notification) dated 22 June 2016 on the effective date of the general anti-avoidance rules (GAAR).According to the Notification, the amendments to the Income Tax Rules, 1962 are: (a) As per Rule 10U(1)(d), the GAAR provisions do not apply to any income accruing or arising to, or deemed to accrue or arise to, or received or deemed to be received by, any persons from the transfer of investments made before 1 April 2017 (previously 30 August 2010); and (b) As per Rule 10U(2), the GAAR provisions apply to any arrangement, irrespective of the date on which it was made, whereby any tax benefit is obtained from such arrangement on or after 1 April 2017 (previously 1 April 2015). See the story in Regfollower |
El Salvador | E-filing: The tax authorities issued Circular DG-001/2016 on 13 June 2016, launching that large taxpayers must file their 2015 financial statements together with the notes and tax report electronically using digital Form F-457 through the Ministry of Treasury’s website. See the story in Regfollower |
Chile | Chile’s Internal Revenue Service (IRS) publishes the last set of Circulars on 13 and 14 July 2016, with instructions on the amendments introduced by the 2015 Simplification Law (Law 20,899, published in February 2016), which simplifies the 2014 Tax Reform(Law No 20,780). CFC: The instructions in Circular No. 40 of 2016 introduces the Controlled Foreign Corporation rules (the CFC rules) which incorporated into the Income Tax Law under Article 41G. GAAR: The instructions in Circular No. 41 of 2016 introduces the General Anti-Avoidance rules (GAAR) which incorporated into the Tax Code. The Circular also summaries the procedure for submitting questions to the Chilean IRS on how GAAR would apply to a hypothetical transaction or group of transactions. Under these instructions, any person may submit questions and the Chilean IRS will respond with a general, non-binding answer that cannot be cited as precedent in a future tax audit. See the story in Regfollower |
World Tax Brief: July 2016
07 August, 2016