Australia | Corporate tax rate: The 2017-18 federal budget has been delivered on 9 May 2017 and the government announced a reduction in the small business tax rate from 28.5% to 27.5% for the 2016–17 income year. The turnover threshold to qualify for the lower rate will start at $10 million (in 2016-17) and progressively rise until the 27.5% rate applies to corporate tax entities with less than $50 million aggregated annual turnover in the 2018-19 income year. From 2017-18, entities eligible for the lower tax rate will be known as base rate entities. Capital gains tax: The Budget for 2017 -18 also proposes the changes to the foreign resident capital gains withholding (FRCGW) rate and threshold. The changes will apply to contracts entered into on or after 1 July 2017, for real property disposals where the contract price is $750,000 and above (currently $2 million) and the FRCGW withholding tax rate will be 12.5% (currently 10%). See the story in Regfollower Central management and control: Recently, the Australian Tax Office has released a new draft ruling TR 2017/D2 and has withdrawn its preceding Ruling TR 2004/15 on the tax residence of foreign incorporated companies. Accordingly, if a company carries on business and has its central management and control in Australia, it will necessarily carry on business in Australia. That is so even when the only business carried on in Australia consists of that central management and control, and its trading operations are conducted outside Australia. See the story in Regfollower |
Canada | Incentives:Â The Canadian government has proposed to extend the small deduction to certain farmers. The small business deduction effectively reduces corporation tax from 15 percent to 10.5 percent on the first CAD500, 000 (USD365, 281) of active business income generated by a Canadian-controlled private company. See the story in Regfollower |
France | Dividends/Profits Distributions: The Court of Justice of the European Union (CJEU) issued a judgment on 17 May 2017, ruling that the 3% contribution on distributed profits is not compatible with article 4-1 of the European Union (EU) Parent-Subsidiary Directive (PSD) when the parent company makes the redistribution of the dividends received from its subsidiaries. See the story in Regfollower Corporate tax rate: French newly elected president has committed to reducing the corporate tax rate from current rate of 33.3% to 25% with the aim to bring it in line with the EU average within five years. See the story in Regfollower |
Italy | Incentives: The Italian revenue on 9 March 2017 provided tax instruction, the clarification of the Italian patent fund regimes, the tax credit for research and development activities (R & D) and the tax credit for new operating assets. See the story in Regfollower |
Singapore | Incentives: Singapore has released Budget for 2017 on 20 February 2017, for the financial year 1 April 2017 to 31 March 2018. The Budget bill raised the existing corporate income tax (CIT) rebate cap from SGD 20,000 to SGD 25,000 for the assessment year 2017, but the rebate rate remains unchanged at 50% of tax payable. This CIT rebate will be extended for another year to YA 2018 but there will be a reduced rate of 20% of tax payable with a cap of SGD 10,000. See the story in Regfollower |
Kenya | Incentives: The Finance Bill, 2017 published on 3rd April 2017 which was announced on 30th March 2017. The Bill has amended various tax provisions while at the same time providing clarity on the existing provisions. As a result, A 150% investment deduction allowance has been introduced for capital expenditure in the economy; 100% investment deduction on capital expenditure added on the construction of a building or machine installation by or for use in the Special Economic Zone. This is aimed at encouraging investment at the SEZs; To encourage investment and the assembly of motor vehicles in Kenya the corporate tax rate is to be reduced from 30% to 15% for the first 5 year for new assemblers who assembling motor vehicles locally; A 150% deduction incentive will be applicable to the fishing sector; A 100% investment deduction will be applied to the special economic zone on buildings and machinery. See the story in Regfollower |
India | Dividend distribution tax: The Supreme Court of India in the case of:Â Godrej & Boyce Manufacturing Company Limited v. DCIT (Civil Appeal No. 7020 of 2011), held that disallowance under Section 14A of the Income-tax Act, 1961 (the Act) would apply to dividend income which is subject to dividend distribution tax (DDT). See the story in Regfollower Computation of taxable income: The Supreme Court of India in the case of:Â Raj Dadarkar and Associates v. ACIT (Civil Appeal No. 6455-6460 OF 2017), held that the income from the sub-licensing of the property is taxable as house property income and not business income. See the story in Regfollower |
Hong Kong | Incentives: Hong Kong introduced new tax rules for aircraft leasing industry to foster the proposed development of Hong Kong as an aircraft leasing centre. See the story in Regfollower |
Czech Republic | Withholding tax on interest: The Czech Republic introduces new withholding tax requirements which contain the withholding tax provisions. The changes will take effect on the 15th day of their publication. There is a reference to the publication date and is July 1, 2017. The new provisions of the withholding tax are in principle for shareholders’ associations and profit-sharing companies and financial institutions that pay interest on these companies. The changes extend the chance of 19% withholding tax on interest on deposits. This new measure requires additional requirements for banks and savings banks and credit institutions. See the story in Regfollower |
Norway | Participation relief: The tax authorities released a binding advance ruling on 4 May 2017, regarding the application of a domestic exemption from dividends to an Irish holding company. The judgment provides that the dividends paid by the Norwegian company to the Irish holding company are exempt from Norwegian withholding tax under the domestic exemption from Norway. To be qualified for the withholding tax exemption, the dividend recipient must be practically identical to certain non-individual assessable person according to the Norwegian Tax Act. See the story in Regfollower |
Malaysia | Sanctions for non-compliance:Â The Inland Revenue Board of Malaysia (IRB) has proposed to increase the rate of penalty to 100% on tax payable on undeclared or under-declared income beginning with effect from 1 January 2018. See the story in Regfollower Audits: On 1 May 2017, the Inland Revenue Board of Malaysia (IRBM) adopted a modified Tax Examination Board. The aim of the revised framework is to ensure that tax audits are conducted fairly, transparently and impartially. The framework outlines the rights and obligations of audit officers, taxpayers and taxpayers in relation to a tax audit. In addition, the objective of the framework is to assist the auditors in carrying out their tasks efficiently and effectively and to assist taxpayers in fulfilling their obligations. See the story in Regfollower |
Hungary | Tax Rate:Â The Hungarian Parliament has approved an increase in the country’s advertising tax. The new legislation will increase advertising revenues from 5.3% to 7.5% as from 1 July 2017. See the story in Regfollower |
South Africa | Tax compliance:Â On 15 May 2017, the South African Revenue Service (SARS) has introduced important changes and improvements to its current dispute settlement process as part of the ongoing commitment to providing a better service to taxpayers. For the first time, SARS has implemented an electronic requirement for reasons via eFiling or SARS branches. The Request for Reasons functionality allows taxpayers to request reasons for an assessment where the grounds provided in the assessment do not sufficiently enable a taxpayer to understand the basis of the assessment and to formulate an objection if the taxpayer is aggrieved by the assessment. See the story in Regfollower |
Nigeria | Late payments of tax due: The Finance Minister on 22 May 2017, announced that 5% increased interest charge would impose from 1st of July 2017 on firms that fail to fulfil their tax obligations as and when due as part of measures to sanction tax defaulters and enhance voluntary compliance on tax obligation. See the story in Regfollower |
Greece | Tax payment procedure: The Parliament of Greece has adopted a draft bill on 11th of April 2017, which contains some amendments to income tax code. Accordingly, the corporate income tax payment needs to be completed by six instalments instead of eight. Note that, the first instalment needs to be paid on the last working day of the month following the filing deadline and the rest of five instalments must be paid by the last working day of the following five months. The first payment shouldn’t be paid during filing of the corporate tax return. See the story in Regfollower |
Poland | Incentives: Government has published an amended draft bill regarding the R&D tax relief. The bill proposes an increase of current income tax deduction from 50% and 30% to 100% depends on the category of eligible costs and the size of the taxpayer. This means that all taxpayers who benefited from the R & D tax exemption are able to save in the income tax PLN 19 to each PLN 100 of qualified costs from 2018 onwards. R&D Tax Relief will come into force on 1 January 2018. See the story in Regfollower |
Netherlands | Withholding tax on dividend:Â On 16 May 2017, the Dutch Government published a public consultation on the previously announced legislative proposals on amendments to the dividend withholding tax rules for holding cooperatives. The Dutch government expects the new amendments to the Dutch Dividend Tax Act (DWTA) to enter into force on 1 January 2018. See the story in Regfollower |
Saudi Arabia | Corporate tax rate: The Government of Saudi Arabia has set a range of income tax rates for producers of oil and hydrocarbons, through a royal decree on 27 March 2017. According to the decree, the tax rate for investments exceeding 375 billion riyals ($99.96 billion) will be 50% and the rates will increase for producers with smaller investments. See the story in Regfollower |
UK | Facilitation of tax evasion: The United Kingdom adopts a new criminal offence for non-compliance with tax evasion. The Criminal Code, which contains the offences, received royal approval on 27 April 2017 and was due to enter into force in September 2017. See the story in Regfollower |
US | Incentives: The IRS has announced that from now “eligible small business start-ups” can elect to apply part or all of their research credit against their payroll tax liability instead of having to apply for the research credit against their income tax liability. See the story in Regfollower |
World Tax Brief: May 2017
05 June, 2017