Namibia | Main corporate tax rate: On 7 March 2018, the Finance Minister presented the Budget for 2018/19 to the parliament. Accordingly, from 2019, the tax rate for betting and gaming entities may increase to 37% from current 32%. Tax Base: On 7 March 2018, the Finance Minister presented the Budget for 2018/19 to the parliament. Accordingly, from 2019, income from commercial activities of charitable, religious, and educational institutions will be subject to corporate taxation (currently exempt from the tax). These institutions must register as taxpayers and submit annual income tax returns. Dividends income: On 7 March 2018, the Finance Minister presented the Budget for 2018/19 to the parliament. The Budget introduced a 10% dividend tax for dividends paid to Namibian residents. Dividends received by Namibian residents or distributions by a close corporation to any Namibian resident member will be affected by the introduction of this tax. See the story in Regfollower |
Australia | Group treatment: On 22 March 2018, the Australian Government’s commitment to ensure multinationals pay the right amount of tax in Australia continued with the passage through Parliament of the Treasury Laws Amendment Bill 2018. This Bill implements recommendations made by the Board of Taxation to improve the integrity and operation of Australia’s tax system, by closing loopholes in the tax consolidation regime which create unintended and inappropriate tax outcomes. See the story in Regfollower |
Belgium | Participation relief: Participation exemption on dividends and capital gains on shares are fully exempt from tax for financial years starting as of 1 January 2018. The exemption is subject to some conditions. Group reporting: From 1 January 2020, Belgium will introduce a tax consolidation regime. Accordingly, companies that are in a tax-paying position can make a group contribution to group companies that are in a loss position, subject to conditions and limitations. The receiving company can offset the group contribution with available tax attributes. CFC rules: The new CFC rules will enter into force for financial years starting as from 1 January 2019. See the story in Regfollower |
Brazil | Incentives- Industry/manufacturing: Brazil released the National Congress Act No. 8 of 14 March 2018 in the Official Journal. The Act extends by 60 Days of Provisional Measure No. 810 of 8 December 2017. This act changes the tax incentive for IT companies investing in research and development (R&D) including reduction of federal tax on finished goods. See the story in Regfollower |
Bulgaria | E filing: From 1 January 2018, all corporate taxpayers are required to submit their corporate income tax returns electronically. See the story in Regfollower |
Canada | Sanctions for tax evasion: The Government of Canada is committed to cracking down on tax evasion and aggressive tax avoidance to ensure a system that is responsive and fair for all Canadians. On March 1, 2018, a revised Voluntary Disclosures Program (VDP) will come into effect to narrow the eligibility criteria to access the Program and to impose additional conditions on applicants, making it more difficult for those who intentionally avoid their tax obligations to benefit from the VDP. See the story in Regfollower |
Costa Rica | Late payments of interest: On 16 March 2018, the Ministry of Finance has increased the interest rate for late payments and refunds of overpayments from 12.8% to 13.73%. See the story in Regfollower |
Hong Kong | Main corporate tax rate: On 28 February 2018, the government presented the budget proposal for the country’s tax year beginning 1 April 2018. The Budget proposed a one-off reduction of 75% of profits tax for the year of assessment (YA) 2017/18. The reduction is limited to HKD 30,000, which is applied to every business. Incentives- Industry/manufacturing: On 28 February 2018, the Financial Secretary delivered the budget proposal for the country’s tax year beginning 1 April 2018. The Budget introduced a proposal of super tax deductions for expenditures on qualifying research and development (R&D) activities. See the story in Regfollower Incentives for small business: On 29 March 2018, the Inland Revenue (Amendment) (No. 3) Ordinance 2018 (the Ordinance) was gazette to implement the two-tiered profits tax rates regime. See the story in Regfollower |
Korea Rep Of | Withholding tax rates: On 13 February 2018, the Korean Ministry of Strategy and Finance released amendments to the tax law. Accordingly, the withholding tax rate will increase from 17% to 19% on the amount of compensation paid to hiring foreign entities. Sanction for tax evasion: Under the amendments, the administrative fines imposed for failure to comply with this obligation have increased to a maximum of KRW 50m (U$46,000), and changed to impose penalties for each instance of non-compliance for both residents and domestic entities. Mitigation of penalties: The threshold on the annual sum amount of compensation paid by user Korean entities reduced to KRW 2b. See the story in Regfollower |
Luxembourg | Incentives- Industry/manufacturing: On 22 March 2018, the bill on the new IP regime was adopted by the Luxembourg Government. The Bill must now be signed into law and published in the Official Gazette to enter into force. Once in force, it is effective from 1 January 2018. See the story in Regfollower |
Poland | Incentives- Industry/manufacturing: On 20 February 2018, the Polish government adopted the plans to offer tax incentives to investors across the country, not just in areas designated as special economic zones (SEZs). The amended regime would allow companies to apply for these benefits to varying degrees for investments in any part of the country, subject to certain criteria in relation to the location of investment, size of investment, rate of employment in the area, etc. For companies that have already obtained SEZ permits, the current incentives and rules would continue to apply up to 2026. See the story in Regfollower |
Puerto Rico | E-filing instructions: On 12 March 2018, the Treasury Department of Puerto Rico has issued guidance for the electronic filing (e-filing) of corporate income tax returns for tax year 2017. See the story in Regfollower |
Russia | Groups-Loss treatment: On 9 March 2018, the Ministry of Finance (MoF) clarified the deduction of losses incurred by consolidated group members. Accordingly, from 1 January 2017 losses incurred by the members of a group may be deducted from the consolidated tax base in the current tax period, but cannot be deducted from more than 50% of the consolidated tax base. The remaining losses are divided between the members of the group and may be carried forward to reduce their tax bases in future periods. For tax periods from 1 January 2017 to 31 December 2020 the tax base in the current tax period (except the corporate tax base subject to reduced corporate income tax rates) may not be reduced by more than 50% by losses brought forward from previous tax periods. See the story in Regfollower |
Saudi Arabia | Appeal: In a recent assessment order, the GAZT indicated that the deadline for filing an appeal will be determined from the date that the assessment order is notified to the taxpayer through the ERAD system. See the story in Regfollower |
Sweden | Main corporate tax rate: On 21 March 2018, the Swedish Government submitted a draft bill regarding corporate income tax changes. Accordingly, the existing corporate income tax rate of 22% would be reduced to 21.4% in 2019 and then further reduced to 20.6% in 2021. Tax base for resident Companies: The government proposes a general limitation of interest deduction in the corporate sector, combined with a reduction of the corporate income tax rate. The deduction limitation is designed in the form of an EBITDA rule with a maximum interest deduction of 30% of EBITDA. Incentives for small business: The government proposal also includes exemptions in favor of small and medium-sized enterprises. See the story in Regfollower |
Switzerland: | Dividends: On 21 March 2018, the Swiss Federal Council issued the dispatch to the Swiss Parliament on the draft legislation for the so-called Swiss Tax Reform Proposal 17 (Swiss Corporate Tax Reform III or CTR III). Under the tax reform, 70% of dividend income from qualified participations would be taxed at the federal level and at least 70% of this income would be taxed at the cantonal level. See the story in Regfollower |
Turkey | Incentives: On 22 February 2018, the Government has published a Decree in the Official Gazette. This decree changes the provincial or regional tax incentives rules. See the story in Regfollower |
US | Late payments of interest: On 7 March 2018, The Internal Revenue Service announced that interest rates for overpaid and underpaid increased for the calendar quarter beginning 1 April 2018. Accordingly, the rates are 4% and 5% for corporate overpayments and underpayments, respectively. The rate for corporate overpayments exceeding USD 10,000 in a tax period is 2.5% on the portion exceeding that amount, and the rate for large corporate underpayments exceeding USD 100,000 is 7%. See the story in Regfollower |
Transfer Pricing Brief: March 2018
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