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Worldwide Tax News

Approved Changes (3)

European Union-Lithuania-Romania

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Council Implementing Decisions Published Authorizing Lithuania's and Romania's Increased VAT Registration Thresholds

The Council Implementing Decisions to authorize Lithuania's and Romania's derogation from Article 287 of the VAT Directive (2006/112/EC) with increased VAT registration threshold was published in the Official Journal of the EU on 14 October 2017. The Lithuania Decision authorizes the country to maintain its increased VAT registration threshold at EUR 45,000. The Romania Decision authorizes the country to further increase its VAT registration threshold to the equivalent in national currency of EUR 88,500. In both cases, the authorization applies from 1 January 2018 until the earlier of 31 December 2020 or the entry into force of a Directive amending the provisions of the VAT Directive on a special scheme for small enterprises.

Poland

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Poland CbC Reporting Notification Form and Guidelines Published

Poland's Ministry of Finance has announced the publication of the final model template for the CbC reporting notification (Form CbC-P), which is provided in an XSD format on the ePUAP platform as well as on the finanse.mf.gov.pl automatic exchange of information page along with guidelines. Actual submission of the form in XML format is available from 19 October 2017 via e-Declarations. The announcement also notes that the CbC reporting notification can be submitted in writing to:

Ministerstwo Finansów (Ministry of Finance)

Departament Poboru Podatków (Tax Collection Department)

ul. Świętokrzyska 12

00-916 Warszawa

For fiscal years beginning no later than 31 December 2016, notification is due within 10 months following the end of the year (first notification due 31 October). For later fiscal years, notification is due by the end of the year.

Switzerland

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Swiss Federal Council Decides on Entry into Force of CbC Act and CbC MCAA

On 18 October 2017, the Swiss Federal Council announced its decision to bring the Federal Act on the International Automatic Exchange of Country-by-Country Reports of Multinationals (CbC Act) into force on 1 December 2017. The Multilateral Competent Authority Agreement on the Exchange of Country-by-Country Reports (CbC MCAA) should also enter into force in December. The Swiss CbC reporting requirements apply from the 2018 fiscal year, although voluntary submission is allowed for the 2016 and 2017 fiscal years. For this purpose, the announcement notes that the Federal Council adopted a declaration on the Mutual Assistance Convention (the basis for multilateral CbC exchange agreement) so that the Convention will apply for the exchange of CbC reports for the 2016 and 2017 fiscal years, albeit restricted to the exchange of voluntarily submitted CbC reports.

Note - The Ordinance on CbC reporting requirements was already approved on 29 September 2017, pending a potential public referendum (previous coverage). Because the referendum deadline expired on 5 October 2017 without a referendum being called, the CbC Act and CbC MCAA can enter into force.

Proposed Changes (3)

Canada

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Canada to Reduce Small Business Tax Rate

According to a release from Canada's Department of Finance, the Government intends to reduce the small business tax rate from 10.5% to 10.0%, effective 1 January 2018, and to 9.0%, effective 1 January 2019. The reduced rate applies on the qualifying active business income of a Canadian-controlled private corporation (CCPC) up to CAD 500,000. To support this change, the Government will take steps to ensure that CCPC status is not used to reduce personal income tax obligations for high-income earners rather than supporting small businesses.

Italy

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Italy Publishes Overview on Budget Plan for 2018

The Italian Government has announced the planned measures for the bill on the State Budget for 2018, which was approved by the Council of Ministers on 16 October 2017. The tax-related measures include:

  • Implementing budget savings in order to avoid triggering current safeguard clauses that would increase the value added tax and excise rates if fiscal targets are missed;
  • Implementing a freeze on local and regional tax rate increases;
  • Introducing a three-year 50% social security contribution reduction for companies that employ young workers; and
  • Extending the 140% depreciation allowance for new plant and machinery (to be reduced to 130%) and the 250% depreciation allowance for investments in digital technology through 2019, as well as certain other regional incentives.

The Budget bill must be submitted to parliament for review/approval, and is likely subject to change. Additional details will be published once available.

Luxembourg

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Luxembourg 2018 Budget Presented to Parliament

On 11 October 2017, Luxembourg's Minister of Finance Pierre Gramegna presented the 2018 Budget bill to parliament. The tax-related measures of the Budget bill are mainly limited to individual taxation matters, including measures to increase flexibility and align the tax treatment of non-resident taxpayers with resident taxpayers. For businesses, highlighted measures include tax rebates for investment in electric and zero-emission vehicles and a tax credit for investment in acquired software.

Click the following link for an announcement on the 2018 Budget (French language) from the Luxembourg government for additional information

Treaty Changes (4)

Azerbaijan-Kazakhstan

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Azerbaijan Ratifies Pending Protocol to Tax Treaty with Kazakhstan

On 11 October 2017, the Azerbaijan president signed the law for the ratification of the pending protocol to the 1996 income and capital tax treaty with Kazakhstan. The protocol is the first to amend the treaty and will enter into force after the ratification instruments are exchanged. Details of the protocol will be published once available.

Czech Rep-Qatar

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Tax Treaty between the Czech Republic and Qatar under Negotiation

On 16 October 2017, officials from the Czech Republic and Qatar began the first round of negotiations for an income tax treaty. Any resulting treaty would be the first of its kind between the two countries, and must be finalized, signed, and ratified before entering into force.

Morocco-Zambia

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Tax Treaty between Morocco and Zambia Signed

According to recent reports, an income tax treaty was signed between Morocco and Zambia on 11 October 2017. The treaty is the first of its kind between the two countries, and will enter into force after the ratification instruments are exchanged. Details of the treaty will be published once available.

Switzerland-Ukraine

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Protocol to Tax Treaty between Switzerland and Ukraine to be Signed

According to a release from the Ukraine Ministry of Finance, officials from Switzerland and Ukraine met on 12 October 2017 to discuss bilateral cooperation and agreed to finalize and sign an amending protocol to the 2000 income and capital tax treaty between the two countries as soon as possible. The protocol will be the first to amend the treaty.

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