World Tax Brief: September 2019

Taiwan	Business income taxation: On 26 August 2019, the Taiwan National Tax Bureau for the Northern Area (NTBNA) published a notice for domestic companies. The Notice clarifies that domestic companies purchasing e-services from a foreign e-commerce company must pay the business tax in accordance with Article 36 of the Business Tax Act. See the story in Regfollower Withholding taxes due: On 9 August 2019, Taiwan’s National Taxation Bureau of the Central Area (NTBCA) has issued a notice clarifying that profit-seeking enterprises should file withholding tax during prescribed period. See the story in Regfollower
Malta	Tax incentive: On 13 August 2019, the Maltese government issued a legal notice 208 introducing the “Patent Box Regime (Deduction) Rules, 2019” for the qualifying Intellectual Property (IP). The patent box system provides additional tax deductions on income from qualifying intangible assets (IP). See the story in Regfollower
Philippines	Tax incentive: On 14 August 2019, the House Committee has approved the administration’s second tax reform package on Corporate Income Tax and Incentives Reform Act (CITIRA), which aims to lower corporate taxation (CIT) and modernize incentives. See the story in Regfollower
Chile	PE rules: On 23 August 2019, the tax reform Bill was passed by the Chamber of Deputies. The tax reform bill includes a new definition of permanent establishments and a new concept for tax deductible expenses. It is expected that the tax reform bill will be adopted before the end of 2019. See the story in Regfollower
Norway	Groups-Loss treatment: On 13 August 2019, the Ministry of Finance published a proposal to amend the group contribution rules regarding EFTA Court rule of 13th September 2017, which found that Norway’s rule violated freedom of establishment rights in cases where there is a final loss in a subsidiary established outside Norway. The proposal includes a limited right to deductions for group contributions from a Norwegian company to its foreign subsidiary. See the story in Regfollower
Pakistan	Main corporate tax rate: On 30 July 2019, the Federal Board of Revenue has issued a Circular which contains important changes to the Income Taxation Act 2001 through the Finance Act 2019. Accordingly, the planned reduction in the corporate income tax rate will be replaced by the 29% rate for the tax year 2019 and subsequent years, although the planned reduction for “small businesses” is maintained as follows: Fiscal year 2019-24%; Tax year 2020-23%; Tax year 2021-22%; Tax year 2022-21%; 2023 and following tax years-20%. See the story in Regfollower
China	Incentives on industry/manufacturing: On 2 August 2019, China’s Ministry of Finance and State Taxation Administration have jointly published Notice No. 63 of 2 August 2019 providing incentives to boost up tourism industry in the Guangdong Hengqin New Area. The notice is effective from 1 January 2019 to 31 December 2019. See the story in Regfollower
France	Main corporate tax rate: On 25 July 2019, the new Digital Services Tax (DST) has been published in the Official Gazette. This new Law modifies corporate income tax rate for large companies. Companies with a turnover of 250 million or more is subject to 33.33% rate (instead of 31% rate deriving from Finance Bill for 2018) for financial year starts from 1 January 2019 to 31 December 2019 on the amount of profits more than EUR 500,000. See the story in Regfollower
India	Reduced rate: On 1 August 2019, India has published the Finance (No. 2) Act 2019 in the Official Gazette, which was approved by the president. Accordingly, the standard corporate tax rate is maintained at 30%, while the maximum income threshold for the reduced corporate tax rate of 25% is increased from INR 2.5 billion to INR 4 billion. Treatment of losses-Carry forward: The loss carry forward limits where there is a change of ownership are amended with effect from 1 April 2020 to provide that even if the conditions (minimum 50% same ownership) for carry forward are not satisfied in case of an eligible start-up, the loss incurred in any year prior to the previous year shall be allowed to be carried forward and set off against the income of the previous year under certain conditions. See the story in Regfollower
Peru	GAAR: On 31 July 2019, the Peruvian Tax Administration (SUNAT) published two resolutions (152-2019/SUNAT and 153-2019/SUNAT) regarding general anti-avoidance rule (GAAR) in the Official Journal. The resolutions are effective from 1 August 2019. See the story in Regfollower
Egypt	Late payments of tax due: On 4 August 2019, the Ministry of Finance issued Decision No 484 of 2019 in the Official Journal. The decision entered into force on 5 August 2019. According to the decision, interest will be calculated after the day of tax return deadline until the payment date. It is also clarified that a challenge or appeal against a tax assessment does not affect the interest liability. See the story in Regfollower
Russia	CFC: On 1 August 2019, the Federal Tax Service has approved the amended CFC and the filing procedure in electronic form. This regulation extends the list of information on foreign organizations required to complete a notification form for participation in foreign organizations. See the story in Regfollower Late payments of tax due: On 26 July 2019, the Russian Central Bank announced its decision to cut its key rate from 7.50% to 7.25% with effect from 29 July 2019. The key interest rate is used to calculate the interest deduction and default interest on overdue taxes. See the story in Regfollower
Uganda	Tax incentive: On 30 June 2019, Ugandan Parliament has passed Income Tax Amendment Act 2019. The tax reform measure introduces a reduction in the minimum investment to USD 50 million from USD 100 million for industrial park developers. See the story in Regfollower
Colombia	Dividends: Recently, the Colombian National Tax Authority (DIAN) published Ruling 014495 of 6 June 2019, which sets out tax of profits in shares or stock dividend. See the story in Regfollower
Argentina	Sanctions for non-compliance: On 18 July 2019, Argentine Federal Secretary of Treasury published Resolution 598/2019 in the official gazette amending Resolution 50/2019 on compensatory and punitive interest rates. See the story in Regfollower
Hong Kong	PE rules: On 19 July 2019, the Inland Revenue Department released Departmental Interpretation and Practice Note 60, which explains the concept of permanent establishment (PE) and the methodology for attributing profits to Hong Kong permanent establishments. See the story in Regfollower