| Australia | Sanctions for tax evasion: The Government of Australia announced double the maximum administrative penalties that can be applied by the Commissioner of Taxation to large companies that enter into tax avoidance and profit shifting schemes. The increased penalties, under Schedule 1 to the Taxation Administration Act 1953, would help to deter tax avoidance and applicable to income years commencing on or after 1 July 2015.
Reduced rates: Under the recent Budget, the government of Australia decreased the income tax rate for small business companies to 28.5 per cent with an aggregated annual turnover of less than AUD 2 million. Companies with an aggregated annual turnover of AUD 2 million or above will continue to be subject to the existing 30 per cent tax rate on all their taxable income. GAAR: The Australian Taxation Office (ATO) released a draft practice statement (PS LA 2005/24 (draft) (the Draft) that deals with the application of the general anti-avoidance rules (GAAR) in Part IVA of the Income Tax Assessment Act 1936 On 13 August 2015. The Draft will replace the current Practice Statement PS LA 2005/24. See the story in Regfollower |
| Austria | Dividend: Under the Tax Reform Act 2015/2016, from 1 January 2016 the withholding tax (WHT) applicable to dividend distributions to non-resident companies will increase to 27.5% (increased from the current rate of 25%) and 25% rate of withholding tax would continue to apply to general bank and savings accounts. |
| Thailand | Other Incentives: The Board of Investment has introduced a new program. According to the program, there will be relief from corporate income tax (0% of non-Thai source income from services, royalties, and dividends, and 10% on certain Thai source income) for a period of 15 years.
Tax incentives for small business: The Cabinet of Thailand approved certain corporate tax rate limits for small and medium-sized enterprises (SMEs) on 8 September 2015. The new corporate income tax limit will become effective as from beginning of 1 January 2015 to 31 December 2016. Also, a five-year corporate income tax exemption will be given to qualifying SMEs that invests in innovation and technology. |
| Mexico: | Incentives for Infrastructure: The Budget proposals for 2016, announced by the Minister of Finance on 8 September 2015 which includes: Incentives for investing in energy and infrastructure sectors. |
| Luxembourg | Group taxation regime: The Luxembourg government released a bill on August 5, 2015. The Bill proposes to expand the tax unity regime to provide for horizontal integration between qualifying companies held by a common parent company that is established in a European Economic Area (EEA) country and is subject to a corporate tax comparable to the Luxembourg corporate income tax (CIT). In addition, it will become possible to include in a group a permanent establishment (PE) of a company established in another EEA country that levies a tax similar to the Luxembourg corporate income tax. |
| Poland | Tax incentives for small business:The parliament approved a bill which states that, the Corporate Income Tax Law to establish new research and development (R&D) tax incentives and promote modern technologies. According to the bill tax relief will be 150% of the R&D expenses for small and medium-sized companies, whereas the tax relief amount of large companies will be 120%. |
| Romania | Dividend: On 10 September 2015 Official Gazette No. 688 published Law No. 227 regarding the Tax Code. According to the revised Code withholding tax on dividends paid by resident companies to resident and non-resident companies will be reduced from 16% to 5%, with effect from 1 January 2017. Rates: A new rate of 1% will be introduced for taxation of newly incorporated micro-enterprises that have at least one employee and are established for at least 48 months, if their shareholders did not own shares in other companies; the current 3% rate remains applicable to micro-enterprises in all other situations. Sanctions for tax evasion: The Romanian tax authority has published the revised Fiscal Procedure Code in the Official Gazette no. 545 dated 23 July 2015. According to the revised Code new penalty level was established at 0.08% per day of delay and can be reduced by 75%, upon request, if the related tax liabilities are paid within the legal deadline provided by the tax assessment decision. Late payment, interest and the level of penalties are reduced to 0.02% and 0.01% respectively. |
| Indonesia | Debt equity ratio permitted:Under the regulation No. 169/PMK.010/2015 issued by the Ministry of Finance, the debt-to-equity ratio under the “thin cap” rules are set at 4:1 maximum for fiscal year 2016. |
World Tax Brief: September 2015
October 05, 2015
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