Worldwide Tax News
According to recent reports, Greek Economy Minister Giorgos Stathakis has stated that Greece will hold the corporate tax rate at 29% for at least the next two years. The rate had been increased from 26% to 29% for tax years beginning on or after 1 January 2015 as a result of Greece's bailout.
Upcoming OECD Webcast on G20 Tax Policy Symposium and Leaders Summit and Multilateral Instrument for Treaty-Related BEPS Measures
The OECD Centre for Tax Policy and Administration will hold a webcast on 22 September 2016 to provide updates on recent and upcoming developments, including:
- Outcomes from the G20 Ministerial Tax Policy Symposium, and the recent Leaders Summit;
- Update on negotiation of the multilateral instrument for tax treaty-related BEPS measures; and
- Tax policy reforms in the OECD area.
Click the following link to the OECD webcast page to register.
European Commission Issues Injunction Suspending Poland's Retail Sales Tax Pending a State Aid Investigation
The European Commission issued an injunction on 19 September 2016, requiring Poland to suspend the application of its new retail sales tax until the Commission finishes an in-depth investigation into concerns that the progressive rates of the tax based on turnover give companies with a low turnover a selective advantage over their competitors in breach of EU State aid rules.
Poland adopted the tax in July 2016, which includes an exemption on monthly retail turnover up to PLN 17 million and a top progressive rate of 1.4% on monthly turnover over PLN 170 million (previous coverage). The tax only entered into force on 1 September 2016 and no payments are yet due.
Click the following link for the release on the Commission injunction and investigation.
On 4 September 2016, new rules entered into force relaxing the conditions for qualified foreign investors (QFI) to invest in the Saudi Stock Market, which was opened up to foreign investment on 15 June 2015 (previous coverage). The main changes include a reduction in the minimum amount of assets the QFI must have under management from SAR 18.75 billion to SAR 3.75 billion and an increase in the permitted ownership in a single company by a single investor and its affiliates from 5% to 10%. In addition, the total percentage of foreign investment a single listed company may have is increased from 20% to 49%.
On 13 September 2016, the Thai Cabinet approved the extension of the reduced VAT rate of 7% until 30 September 2017. From 1 October 2017, the government is planning to revert to the standard 10% rate, which was temporarily reduced as the result of special economic measures taken after the 1997 Asian financial crisis. However, given that the reduced rate has been extended several times over the years, it is uncertain if reverting back to 10% in October 2017 will actually happen.
On 19 September 2016, a correcting amendment to the U.S. Country-by-Country reporting final regulations (TD 9773) was published in the Federal Register. The amendment corrects an internal reference in paragraph (d)(3)(iv) regarding the tax paid and tax expense accrued of a permanent establishment.
On 16 September 2015, the Canadian Department of Finance announced the release of draft legislative and regulatory proposals relating to technical amendments to the Income Tax Act and related legislation. According to the announcement, the main proposed amendments include:
- Improving the accuracy and consistency of the income tax legislation and regulations;
- Extending the types of reverse takeover transactions to which the corporate acquisition of control rules apply;
- Improving the consistency of rules applicable for expenditures in respect of scientific research and experimental development;
- Introducing new rules to ensure that the taxable income of federal credit unions will be allocated among provinces and territories using the same allocation formula as applicable to the taxable income of banks; and
- Ensuring the appropriate application of Canada’s international tax rules, including by:
- Making largely relieving changes to the “upstream loan” rules (and related transitional relieving rules);
- Re-introducing previously proposed rules to ensure an appropriate income inclusion for stub-year foreign accrual property income on dispositions of foreign affiliate shares;
- Introducing a new elective rule that provides tax-deferred treatment in respect of dispositions of taxable Canadian property on a foreign merger;
- Making generally relieving changes to the shareholder benefit rules as they apply to foreign corporate reorganizations; and
- Clarifying the taxation of dispositions of taxable Canadian property resulting from a “negative adjusted cost base” in a property.
On 15 September 2016, officials from Austria and Liechtenstein signed a protocol to the 1969 income and capital tax treaty between the two countries. According to a release from the Liechtenstein government, the protocol amends Article 19 (Government Services) to clarify the taxing rights of the State acting as the employer, and amends Article 25 (Mutual Agreement Procedure) to implement the minimum standard developed under BEPS Action 14 (Make Dispute Resolution Mechanisms More Effective).
The protocol is the second to amend the treaty, and will enter into force after the ratification instruments are exchanged.
On 13 September 2016, the Jersey parliament approved the pending income tax treaty with the United Arab Emirates. The treaty, signed 20 April 2016, is the first of its kind between the two countries. It will enter into force once the ratification instruments are exchanged, and will apply from 1 January of the year following its entry into force.
Click the following for details of the treaty.
Singapore and the UK Sign Competent Authority Agreement for Exchange of Financial Account Information
On 16 September 2016, officials from Singapore and the UK signed a competent authority agreement for the automatic exchange of financial account information based on the OECD Common Reporting Standard (CRS). Under the agreement, each country will automatically exchange information on accounts held in the respective country by tax residents of the other country. The automatic exchange is to begin by September 2018.