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Hong Kong: New guidance for corporate treasury centres in Hong Kong

The Hong Kong government gazetted the Inland Revenue (Amendment) (No. 2) Ordinance 2016 (the Ordinance) on June 3 2016, bringing into law a concessionary profits tax rate for qualifying corporate treasury centres (QCTCs). The new rules deem certain interest income and other gains as sourced and taxable in Hong Kong. Amendments to the earlier interest deduction provisions were also made to allow deductions for interest incurred on certain intra-group lending transactions.

October 26 2016

Curaçao: Tax rules for businesses to change as budget law is approved by parliament

The Curaçao tax budget was approved by parliament on July 23 2016 and published in PB 2016 No. 37. The changes will come into force by a separate state decree (Landsbesluit). At the time of writing, only the provisions to stimulate pension savings have come into force.

October 26 2016

Albania: Albanian transfer pricing regulations

Transfer pricing (TP) rules have been present for more than a decade in the Albanian Corporate Income Tax (CIT) Law, but specific and detailed regulations on the application of these rules were only published in the Official Journal No. 70, dated May 20 2014. These changes have totally transformed Article 36 of the Law on Income Tax (No. 8438, dated December 28 1998) by adding seven more provisions on specific rules and actions.

October 26 2016

Bulgaria: Bulgarian transfer pricing regulations

Bulgaria fully applies the OECD Transfer Pricing (TP) Guidelines and has had robust TP rules for several years.

October 26 2016

US Inbound: US Treasury issues final regulations on tax treatment of corporate debt

The US Treasury and the IRS have released final regulations under Internal Revenue Code, section 385. They are an improvement over the regulations proposed in April 2016, but still contain many developments that should be noted by inbound organisations.

October 26 2016

Canada: Canada introduces draft legislation to broaden back-to-back rules to character substitution transactions

The 2016 Canadian federal budget proposed to significantly broaden certain rules aimed at preventing the use of back-to-back (BTB) loans to circumvent Canadian tax rules governing the withholding tax treatment of interest payments made in relation to certain transactions involving intermediaries and non-arm's length non-residents.

October 26 2016

Switzerland: UK’s hybrid mismatch rules to impact Swiss entities

The UK's new legislation to tackle hybrid mismatches, which enters into force on January 1 2017, may impact certain Swiss principal structures that are benefitting from a so-called Circular No. 8 regime.

October 26 2016

Australia: Australia increases focus on MNE tax avoidance and BEPS initiatives

Recent announcements by the Australian Taxation Office (ATO), including statements by two senior ATO officers, confirm the significant focus on multinational tax avoidance and BEPS-related initiatives by the ATO and more broadly by the Australian government.

October 26 2016

Taiwan to introduce VAT for online foreign retailers

Taiwan is to become the latest country to levy a VAT on online foreign retailers, following similar OECD-inspired laws introduced by the EU and countries including Japan, Russia, South Korea, Australia and New Zealand.

Joe Stanley-Smith, October 26 2016

Businesses rush to prepare for UAE VAT

The United Arab Emirates is on target to implement its VAT regime on January 1 2018, but with the final VAT Law yet to be published, businesses face a tight deadline to make sure they have the tools to comply with the new system.

Anjana Haines, October 26 2016

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