The Tax Hub

Daily Tax Newsletter

Worldwide Tax News

Approved Changes (1)

Costa Rica

Responsive image

Costa Rica Publishes Law Reintroducing Registration Tax

On 22 March 2017, Law No. 9428 was published in Costa Rica's Official Gazette, which implements a new version of the country's annual registration tax on companies, which was found unconstitutional in January 2015 (previous coverage). Under the new version, the registration tax will be levied as follows:

  • For companies, including branches of foreign companies, that are registered in the register of legal entities but are neither declarants nor taxpayers, the registration tax is equal to 15% of the monthly base salary;
  • For companies with declared gross income of less than 120 monthly base salaries in the tax period, the registration tax is equal to 25% of the base salary;
  • For companies with declared gross income of 120 monthly base salaries up to 280 base salaries in the tax period, the annual registration tax is equal to 30% of the base salary; and
  • For companies with declared gross income exceeding 280 monthly base salaries in the tax period, the annual registration tax is equal to 50% of the base salary.

The registration tax is to be paid within 30 days of the beginning of each calendar year and is non-deductible. Penalties will apply for failing to pay the tax, and the dissolution of a company will result if not paid for three consecutive periods.

The monthly base salary in 2017 is CRC 426,200 (~USD 770).

Proposed Changes (3)


Responsive image

Canada Federal Budget 2017 Tabled

Canada's Federal Budget 2017 was tabled by Finance Minister Bill Morneau on 22 March 2017. The business related tax measures proposed in the Budget include:

  • Measures related to investment fund mergers, including:
    • Extending the mutual fund merger rules to facilitate the reorganization of a mutual fund corporation that is structured as a switch corporation into multiple mutual fund trusts on a tax-deferred basis;
    • Allowing insurers to effect tax-deferred mergers of segregated funds and allowing segregated funds to carry over non-capital losses;
  • Extending the scope of eligible equipment for accelerated capital cost allowance for clean energy generation equipment;
  • Measures related to Canada development expense (CDE) and exploration expense (CEE), including:
    • Reclassifying most expenditures related to drilling or completing a discovery well as CDE (deducted at 30% per year on declining-balance basis) instead of CEE (deducted in full in year incurred);
    • No longer allowing small oil and gas corporations to treat the first CAD1 million of CDE as CEE;
  • Clarifying that in determining whether de facto (factual) control of a corporation exists, the factors that may be considered are not limited to factors that include a legally enforceable right to effect a change to the board, or to exercise influence of shareholders;
  • Measures related to the timing of recognition of gains and losses on derivatives, including:
    • Introducing an elective mark-to-market regime for derivatives held on income account;
    • Introducing a specific anti-avoidance rule that targets straddle transactions;
  • Eliminating certain incentives, including
    • The 50% additional deduction for donations of medicine;
    • The investment tax credit for child care spaces;
    • The tax exemption for insurers of farming and fishing property;
  • Eliminating the ability for designated professionals to elect to use billed-basis accounting;
  • Extending the base erosion rules to foreign branches of life insurers to ensure that Canadian life insurers are taxable in Canada with respect to their income from the insurance of Canadian risks; and
  • Amending the definition of a taxi business to require providers of ride-sharing services to register for the GST/HST and charge tax on their fares in the same manner as taxi operators.

Click the following link for the main Budget 2017 webpage and the Tax Measures: Supplementary Information.

United Kingdom

Responsive image

UK HMRC Opens Several Consultations and Publishes Outcomes of Several Others

UK HMRC has opened several consultations on certain measures announced in the Spring Budget 2017, but not included in the 2017 Finance Bill, and has published the outcomes of several consultations that have closed. Newly opened consultations include:

Consultation outcomes published include:

Click the following link for all consultations published by HMRC.

United States-Puerto Rico

Responsive image

U.S. Bill to Extend Puerto Rico Domestic Production Activities Deduction Permanently

Puerto Rico's Resident Commissioner Jenniffer Gonzalez-Colon has submitted Bill H.R.1403 in the U.S. House of Representatives that would make permanent the 9% deduction for domestic production activities in Puerto Rico (Section 199 deduction). The bill would strike subparagraph (C) of Section 199(d)(8) of the Internal Revenue Code, which currently provides that with respect to Puerto Rico activities, the deduction applies for the first 11 taxable years of the taxpayer beginning after 31 December 2005 and before 1 January 2017.

Treaty Changes (5)


Responsive image

Argentina and Brazil Sign Agreement for Automatic Exchange of Financial Account Information

Brazil's Federal Revenue Department has announced that an agreement for the automatic exchange of financial account information was signed with Argentina on 17 March 2017. According to the announcement exchange under the agreement will be in accordance with the Convention on Mutual Administrative Assistance in Tax Matters.


Responsive image

Bahrain Ratifies Pending Tax Treaty with Bangladesh

Bahrain reportedly ratified the pending income tax treaty with Bangladesh on 21 March 2017. The treaty, signed 22 December 2015, is the first of its kind between the two countries (previous coverage). 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.


Responsive image

Pakistan Rules Finalized for Implementation of Common Reporting Standard for Exchange of Financial Account Information

On 15 March 2017, the Pakistan Federal Board of Revenue issued Notification S.R.O. 166 (I)/2017 on final amendments to the Income Tax Ordinance for the implementation of the OECD's Common Reporting Standard (CRS) for the automatic exchange of financial account information. Under CRS, countries collect information on financial accounts of non-resident's and exchange that information with the respective countries that have also adopted the standard and have entered into an agreement for exchange.


Responsive image

New Tax Treaty between Pakistan and Switzerland Signed

On 21 March 2017, officials from Pakistan and Switzerland signed a new income tax treaty. Once in force and effective, the new treaty will replace the 2005 tax treaty between the two countries.

Taxes Covered

The treaty covers Pakistan income tax, the super tax, and the surcharge. It covers Swiss federal, cantonal, and communal taxes on income, including total income, earned income, income from capital, industrial and commercial profits, capital gains, and other items of income.

Service PE

The treaty includes the provision that a permanent establishment will be deemed constituted when an enterprise furnishes services within a Contracting State through employees or other engaged personnel for the same or connected project for a period or periods aggregating more than 183 days within any 12-month period.

Withholding Tax Rates

  • Dividends - 10% if the beneficial owner is a company that directly holds at least 20% of the paying company's capital; otherwise 20%
  • Interest - 10%
  • Royalties - 10%
  • Fees for Technical Services (managerial, technical or consultancy) -7%, provided that Switzerland does not, according to its inland law, levy a tax at source on payments for services paid to nonresidents; otherwise 10% (conditional 7% rate provided in final protocol to the treaty)

Capital Gains

The following capital gains derived by a resident of one Contracting State may be taxed by the other State:

  • Gains from the alienation of immovable property situated in the other State;
  • Gains from the alienation of movable property forming part of the business property of a permanent establishment in the other State; and
  • Gains from the alienation of shares in a company deriving more than 50% of their value directly or indirectly from immovable property situated in the other State, with an exemption for shares listed on a stock exchange in either Contracting State (or other exchange agreed to) and an exemption if the company caries on its business in the property.

Gains from the alienation of other property by a resident of a Contracting State may only be taxed by that State.

Double Taxation Relief

Pakistan applies the credit method for the elimination of double taxation, while Switzerland generally applies the exemption with progression method. However, in respect of income covered by Articles 10 (Dividend), 11 (Interest), 12 (Royalties), and 13 (Fees for Technical Services), Switzerland may allow a deduction of the Pakistan tax paid (not exceeding Swiss tax), a lump sum reduction of the Swiss tax, or a partial exemption. In addition, a Swiss resident company deriving dividends from a Pakistan company will be entitled to the same relief that would be granted to the Swiss company if the company paying the dividends were a resident of Switzerland.

Entitlement to Benefits

Article 26 (Entitlement to Benefits) provides that a benefit of the treaty will not be granted if it is reasonable to conclude that obtaining that benefit was one of the principal purposes of any arrangement or transaction that resulted directly or indirectly in that benefit, unless it is established that granting that benefit in these circumstances would be in accordance with the object and purpose of the relevant provisions of the treaty.

Entry into Force and Effect

The treaty will enter into force once the ratification instruments are exchanged and will apply in Pakistan from 1 July of the year following its entry into force and in Switzerland from 1 January of the year following its entry into force. The 2005 tax treaty between the two countries will terminate upon the entry into force of the new treaty and will cease to have effect for the following fiscal year.

United Kingdom-Germany

Responsive image

UK-Germany Bank Levy Double Taxation Agreement Terminated

According to a 16 March 2017 update from UK HMRC, the Bank Levy Double Taxation Agreement with Germany was terminated on 20 February 2017 with effect from 1 January 2015, the date of entry into force of EU Directive 2014/59.


Powerful Tax Tools


FX Rates

Global FX Rates including Tax Year Average FX Rates and Spot Rates for all Reporting Currencies.


Corporate Tax Rates

Corporate tax rates, surtaxes, and effective tax rates for the current year, as well as historical rates and approved future rates.


Country Analysis

Detailed tax guidance for companies doing business in over 100 countries, including summaries and snapshots of key tax facts and issues.


Cross Border Tax Calculator

Calculate total tax costs and benefits of a cross border transaction including withholding tax, participation exemption and foreign tax credit rules.


Cross Border Tax Rates

Provides Domestic, treaty and EU cross border tax rates for over 5,000 country combinations for 9 different payment streams.



Complete overview of the OECD BEPS Project, including daily BEPS news, country adoption of BEPS measures, and an overview of the 15 BEPS Actions.


Tax Calendar

Customizable calendar tool that tracks corporate income tax, value added tax and transfer pricing obligations by country or entity.


Tax Forms

English translations of key tax forms for over 80 countries, including tax return forms, treaty benefit forms, withholding tax forms, and more.


Worldwide Tax Treaties

Repository including thousands of tax treaties (in English), OECD, UN and US Models, relevant EU Directives, Technical Explanations, and more.


Worldwide Tax Planner

Calculates the worldwide tax cost of what-if scenarios based on legal entity structure, taxable income, and cross border transactions.


Certified Rates Report

Customizable Certified Rates Report providing updated corporate and withholding tax rates at the end of each month for over 100 countries.


Withholding Tax Minimizer

Enables quick calculation of tax costs and benefits of cross border transactions considering all possible transaction combinations and optimal routes.


VAT Rates

Provides value added tax (VAT) rates, goods and services tax (GST) rates and other indirect tax rates for over 100 countries.


NOL Calculator

Country specific calculator to determine how net operating losses can be utilized in carryback and carryforward years.


Transfer Pricing Calculator

Calculates TP ratios under various TP methods and calculates the difference between target ratios and actual ratios.


Individual Income Tax Rates

Individual tax rates for over 100 countries.

Play of the Day

Compare Forms

English translations of key tax forms for over 80 countries, including tax return forms, treaty benefit forms, withholding tax forms, and more.

Get Started with Orbitax Today

With Orbitax, you get reliable and comprehensive solutions for international tax research, compliance and planning. Contact us today to get started with Orbitax.

We’re here to help

We’re here to answer any questions you have about the Orbitax products and services.

Send us a message

Who’s behind Orbitax?

We’re committed to providing high value, low cost tax research and management solutions.

Learn More