Hong Kong | Incentives for industry/manufacturing: On 27 February 2019, the Secretary of State presented the 2019/2020 Budget to the Legislative Council. The budget cuts profit tax for 2018/19 by 75%, subject to a ceiling of HKD 20,000, giving companies with profit taxes of HKD 26,667 or more a profit of HK $ 20,000. The budget also introduced concessional measures under the SME Financing Guarantee Scheme. See the story in Regfollower Submission of returns: On 18 February 2019, the Hong Kong Inland Revenue Department has published the sample Profit Tax Returns for 2018/2019 including other supplementary forms. |
Slovak Republic | Incentives for industry/manufacturing: On 21 February 2019, the government of Slovak Republic has proposed to amend the research and development (R&D) tax regime. According to proposal, qualified corporations would be eligible for a 150% deduction from their qualifying taxable profits in 2019, it will increase up to 200% in 2020 (currently 100). See the story in Regfollower |
Luxembourg | PE rules: On 22 February 2019, Luxembourg tax authorities issued a new circular that clarifies recently added the new Permanent Establishment (PE) definition as set forth in article 16(5) of the Tax Adaptation Law. Under the new paragraph, the Tax Authorities may require a taxpayer to prove that the other Contracting State actually recognizes a PE in its territory. The new paragraph applies to tax years beginning on or after 1 January 2019. See the story in Regfollower |
Portugal | Tax payment procedure: On 31 December 2018, Portugal published 2019 budget law in the official gazette and generally applies as from 1 January 2019. Taxpayers that have submitted a corporate income tax return and an annual declaration in accordance with Portuguese tax legislation for the two previous fiscal years may be exempt from the special payments on account.
Filing return: If a company no longer trades, the deadline for filing the corporation tax return and annual return and preparing the tax file with all necessary tax documents for the year until the last day of the following third month will be extended to the date on which the activity ceases. Previously, the deadline was the last day of the month in which the activities were stopped. Tax incentives: Under the investment support tax regime to taxpayers that carry out a relevant investment is 25% on the first EUR 15 million and 10% on amounts exceeding EUR 15 million (previously, the threshold was EUR 10 million). Furthermore, the tax incentive system for research and development is extended to include contributions to public and private investment funds established to invest in companies dedicated mainly to research and development. |
South Africa | CFC rule: On 20 February 2019, the Budget for 2019-20 was presented to Parliament by the Minister of Finance. The Budget proposed to revise the controlled foreign company high tax exemption threshold with a view to reducing it from the current 75%.
PE rules: The budget also proposed to amends the definition of “permanent establishment” in domestic legislation in line with South Africa’s options under the BEPS Multilateral Instrument. |
Peru | CFC rule: On 7 February 2019, the Peruvian Tax Authority was published a report (097-2018-SUNAT / 7T00000) clarifying the passive net income attribution of CFC rules to its Peruvian shareholders. See the story in Regfollower |
UK | Incentives: On 12 February 2019, the UK Finance Act 2019 received the Royal Assent. New provisions applying from 1 April 2019 partly reverse the restriction on tax deductibility for acquisitions of goodwill. Relief will be available for acquisitions of goodwill at a fixed rate of 6.5% of cost each year, but not for related party acquisitions. There will be a cap on the relief amounting to six times the value of other intellectual property assets acquired with the goodwill. This will ensure that no relief is available for goodwill if the relevant transfer did not also include other types of intangible asset.
Taxation of capital gains tax for non-residents: The UK Finance Act 2019 received the Royal Assent on 12 February 2019. The Act introduces changes to ensure that non-residents are liable for tax on capital gains on the sale of all immovable UK property. The provisions cover tax on capital gains of non-residents disposing of an interest in UK land (with some exceptions); and non-residents disposing of assets deriving 75% of their value from UK land. |
Singapore | Incentives for industry/manufacturing: On 18 February 2019, the Finance Minister of Singapore delivered the Budget for 2019. The budget proposed, the 100% Investment Allowance under the Automation Support Package will be extended by two years to maintain support to companies in their automation, productivity and scale-up efforts. See the story in Regfollower |
Italy | Submission of return: On 30 January 2019, Italy’s tax authority issued two protocols and approved the corporate income tax return form and regional tax on productive activities return form to be used for tax year 2018. See the story in Regfollower |
Bulgaria | Submission of return: On 4 February 2019, the National Revenue Agency (NRA) has published the annual tax return with BARCODE on the website of NRA. Detailed instructions for downloading, completing and submitting the statement are added to the form. See the story in Regfollower |
Belgium | Thin capitalization rule: On 31 January 2019, the parliament of Belgium approved legislation implementing the 30% of Earnings before interest, tax, depreciation and amortization (EBITDA) restriction on interest deduction to 1 January 2019. The restriction is according to the EU Anti-Tax Avoidance Directive, with an effective date of 1 January 2020. See the story in Regfollower |
Kazakhstan | Submission of return: On 1 January 2019, the Ministry of Finance has introduced new corporate tax return (form 150.00). The updated form is used for the preparing of tax returns for the reporting year 2018. See the story in Regfollower |
Argentina | Interest on late payment: On 8 February 2019, the Ministry of Economy amends the applicable interest rates for failure to pay and late payment of taxes by a resolution. The decision stipulated that the current monthly interest rate of 3% and the punitive interest rate of 4% would apply until 28 February 2019. From 1 March 2019 to 31 March 2019, the compensatory interest rate will increase to 4.5% and the punitive rate will increase to 5.6%. See the story in Regfollower |
Dominican Republic | Incentive for small business: On 23 January 2019, the Dominican Republic’s Directorate General of Internal Revenue announced a proposal to re-issue the simplified tax regime for micro-enterprises. See the story in Regfollower |
Transfer Pricing Brief: March 2019
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