Chile | Business income taxation: On 21 August 2018, the Chilean president announced that a bill on tax reform would be submitted to Congress. The tax reform laws would propose a single integrated corporate tax system that would eliminate the double taxation of corporate profits (at the corporate level and in the hands of shareholders or owners) under a full credit balance. Accordingly, the taxes paid by the company would be deductible from the taxes payable by owners and shareholders. Main corporate tax rates-Reduced rate: On 21 August 2018, the Chilean president announced that a bill on tax reform would be submitted to Congress. The bill proposed a 25% reduced rate of income tax for small and medium sized enterprises. See the story in Regfollower |
Egypt | Late payments of tax due: On 15 August 2018, the Egyptian Government has issued new Law no. 174 of 2018 (the Law) that reduces late payment interest and penalties by a certain percentage based on the payment day of the taxes due. The law introduces 90% reduction on interest and penalties if paid by 12 November 2018, a 70% reduction if paid by 27 December 2018, and a 50% reduction if paid by 10 February 2019. See the story in Regfollower |
Finland | CFC rule: On 9 August 2018, the Ministry of Finance officially submitted its budget proposal for next year 2019. The budget introduced changes to the CFC definition and applicable exemptions, including reducing the control threshold for a company that qualifies as a CFC from the current 50% (direct or indirect ownership) to 25% of ownership of share capital or voting rights or profit entitlements as defined by ATAD (Anti-Tax Avoidance Directive). The new rules would enter into force on 1 January 2019 and be applied for the first time in relation to the taxation of 2019. See the story in Regfollower |
Venezuela | Incentives for industry/manufacturing: On 2 August 2018, Venezuela had published Decree No 3,569 of 1 August 2018 in the Official Journal. The law provides for a one-year tax exemption on hydrocarbon Production activities for the Venezuelan state oil and gas company and its affiliates, as well as for joint ventures, whether or not they are based in Venezuela. See the story in Regfollower |
Australia | Thin capitalization rules: On 1 August 2018, the Australian Treasury released an exposure draft law on the two thin capitalization measures announced in the 2018/19 Federal Budget. The changes are: (i) requiring entities to align the value of their assets for thin capitalization purposes with the value included in their financial statements; and (ii) ensuring that foreign controlled Australian consolidated entities and multiple entry consolidated groups that have foreign operations are treated as both outward and inward investing entities. The two changes apply from income years commencing on or after 1 July 2019. See the story in Regfollower Tax base-Reduced rate: The eligibility has changed for the lower company tax rate in Australia. This means the definition of a base rate entity has changed by replacing the ‘carrying on a business’ requirement with a passive income test. See the story in Regfollower |
Poland | Withholding tax: Polish Ministry of Finance has proposed significant changes in the tax law under 2019 tax reform proposal. The proposal introduced a tightening of requirements for the application of withholding tax exemption on dividend, interest and royalty payments or preferential interest rates based on tax treaties. See the story in Regfollower |
Colombia | Main corporate tax rate: Recently, a tax reform bill was submitted by a political party to Congress for analysis. The Bill proposed to reduce the corporate income tax rate to 30% from 33%. Carry forward-Ordinary losses: Recently, a tax reform bill was submitted by a political party to Congress for analysis. The bill proposed to eliminate the current 12 years limitations for carrying forward net operating losses (NOLs). Dividends: Recently, a tax reform bill was submitted by a political party to Congress for analysis. The bill proposed dividends, currently taxed at a 5% rate, would not be taxed when remitted abroad. Dividends paid from profits not taxed at the corporate level would be taxed at a 30% rate. See the story in Regfollower Late payments of tax due: According to an Administrative Regulation 1112 of 2018, Colombia has updates late payment interest rate for September 2018. The effective monthly interest rate for late payment of taxes has been set at 27.72% and valid from 1 to 30 September 2018. See the story in Regfollower |
Peru | Taxability of other income-Nonresident: On 2 August 2018, Peru’s Ministry of Finance published Legislative Decree No. 1369 regarding amendments in relation to deductions for royalties and service fees paid to non-residents. See the story in Regfollower |
Croatia | Incentives: On 18 July 2018, Croatia published the Law on State Aid for Research and Development Projects in the Official Journal. The law introduces a new incentive system for R & D projects, which includes increased deductions for R & D costs. The law entered into force on 26 July 2018 and a regulation containing further directives for the application of the law should be adopted within 90 days. See the story in Regfollower |
Russia | Local tax rate: The Russian Government amended the regional corporation tax rate and published it on 3 August 2018 in the Official Journal. The amendments permit the various regions to repeal the minimum rate of 13.5% in force in their territory from 1 January 2019. See the story in Regfollower |
Korea Rep Of | Carry forward-Ordinary losses: On 30 July 2018, the South Korean Ministry of Economy and Finance published an overview of the proposed 2018 tax Revision Bill. The tax amendments of 2019 have proposed to reduce the loss carryforward offset limit for foreign corporations from 80% to 60% from 1 January 2019 (already scheduled for domestic corporations). See the story in Regfollower |
Romania | Dividends: On 10 July 2018 the Romanian legislature passed Law no 163/2018 in the Official Gazette allowing quarterly dividend distributions. Accordingly, from now Romanian companies will be able to distribute dividends on a quarterly basis. The Law amended the Accounting Law 1991 and the Companies Law 1990 to provide companies with the option to distribute profits (dividends) on a quarterly basis. See the story in Regfollower |
Spain | Incentives: On 4 July 2018, the Spanish government has published Law 6/2018 in the official gazette. The law, which implements the tax measures from the fiscal year 2018 state budget, entered into force on 5 July 2018. The budget includes changes to the patent box regime and to the corporate income tax installment payment calculations for venture capital entities. See the story in Regfollower |
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Transfer Pricing Brief: September 2018
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