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Sponsored by DLA Piper AustraliaIn recent weeks, we have seen important Australian tax developments that are relevant to multinationals and inbound investments. With many initiatives taking effect as early as January 1 2019, multinationals should consider the potential impact on their inbound and outbound Australian investments.
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Sponsored by KPMG Hong KongIn recent years, there have been various accounting changes which have had significant tax implications on how certain items are accounted for and potentially taxed. The two main changes in Hong Kong have been HKFRS 9 (affecting financial instruments) and HKFRS 16 (leases).
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Sponsored by KPMG ChinaAt an executive meeting of China's State Council on July 23 2018, Premier Li Keqiang announced that the country would expand the scope of the 75% corporate income tax (CIT) super deduction for eligible research and development (R&D) expenses to cover all resident enterprises. This super deduction rate currently applies to defined science and technology-related small and medium-sized enterprises (SMEs), while other enterprises can obtain a 50% super deduction. The announced changes will abolish the 50% super deduction incentive. The details of the expanded incentive are still pending, and it remains to be seen whether the increased super deduction rate can be applied retroactively and whether the scope of deductible expenses will be expanded further. This improvement to the super deduction follows the enhancement of the incentive in June's Cai Shui (Circular) 64, to cover R&D work outsourced by Chinese enterprises to foreign providers.
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Sponsored by EY RomaniaIn recent years, due to the fairly low percentage of tax collection, the Romanian tax authorities (RTA) have increased pressure on revenue collection by various means.
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Sponsored by PwC ChileAs a rule, remuneration for services – digital or otherwise – rendered by a non-resident non-domiciled in Chile to Chilean taxpayers are subject to a withholding tax, with rates of up to 35% over the full paid amount depending on the type of service.
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Sponsored by Webber WentzelChanges made last year to South Africa's dividend stripping rules have effectively eliminated the ability of group companies to make use of the rollover relief provisions that historically have allowed qualifying liquidations or deregistration of group companies (both local and foreign) to be done on a tax-neutral basis.
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Sponsored by Garrigues PortugalA recent Portuguese Arbitration Court decision (Case 639/2017-T), dealing with the application of the exemption method to foreign-based liquidation proceeds for non-habitual tax residents serves as a good illustration of how this domestic exemption works.
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Sponsored by Dhruva AdvisorsThe Income-tax Act, 1961 was amended in 2012 such that non-resident taxpayers are not entitled to claim relief under a tax treaty unless they obtain a tax residency certificate (TRC) from their country of residence. But a recent court ruling has changed the situation.
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Sponsored by Deloitte SwitzerlandOn June 25 2018, an amendment to Directive 2011/16/EU (DAC6), came into force, which may have a significant impact on Swiss entities.