Embed Size (px)
Citation preview
www.pwc.com/its
International Tax NewsEdition 59January 2018
WelcomeKeeping up with the constant flow of international tax developments worldwide can be a real challenge for multinational companies. International Tax News is a monthly publication that offers updates and analysis on developments taking place around the world, authored by specialists in PwC’s global international tax network.
We hope that you will find this publication helpful, and look forward to your comments.
Shi‑Chieh ‘Suchi’ LeeGlobal Leader International Tax Services NetworkT: +1 646 471 5315E: [email protected]
www.pwc.com/its
In this issue
Legislation EU/OECDAdministrative Treaties
www.pwc.com/its
LegislationCosta Rica
Costa Rica tax reform
On November 9, 2017, Costa Rica published a bill to strengthen the economy. The bill’s key tax features follow:
• Capital gains derived from the sale of shares issued by a Costa Rica company would be subject to capital gains tax at a 15% rate. Currently, capital gains are not subject to capital gains tax in Costa Rica.
• The bill would abolish the existing sales tax. Currently, the sales tax applies to the sale of goods and the supply of very specific services (such as restaurants and repair shops) at a 13% rate.
• The bill would introduce a value added tax (VAT). It would apply to the supply of services and the sale of goods. The proposed standard VAT rate is 13%.
Currently, the permanent commission of juridical affairs is reviewing this bill.
PwC observation:Given the wide scope, nature, and relevance of the proposed changes, multinational enterprises (MNEs) may need to monitor the bill’s legislative process and revisit their Costa Rica investments.
John A SalernoUSAT: +1 203 539 5733E: [email protected]
Ramon MulleratSpainT: +34 915 685 534E: [email protected]
Carlos BarrantesCosta RicaT: +506 2224 1555E: [email protected]
www.pwc.com/its
El Salvador
Tax amnesty in El Salvador
The Salvadoran government recently approved Legislative Decree No. 804, which contains a tax amnesty program. The program’s key tax features follow:
• The program applies for taxpayers that want to amend taxes and custom duties.
• Mainly, the program applies to those taxpayers that (i) filed tax returns but did not make the relevant payments or (ii) did not file the correspondent tax returns. Taxpayers may also file returns that correct previously filed returns.
• In general, interest, surcharge, or penalties would not apply to taxpayers applying for the tax amnesty program.
• The tax amnesty program does not apply to taxpayers who are part of a tax criminal process.
• The tax amnesty program applies for taxes and customs duties due before October 27, 2017.
• The tax amnesty program has been extended; it now is available until March 15, 2018.
PwC observation:MNEs should review their tax situation in El Salvador and determine whether they could benefit from the tax amnesty program.
John A SalernoUST: +1 203 593 5733 E: [email protected]
Ramon MulleratSpainT: +34 915 685 534 E: [email protected]
Edgar MendozaEl SalvadorT: +502 2420 7800 E: [email protected]
www.pwc.com/its
France
France introduces temporary corporate surtax for large companies while decreasing the standard CIT rate
Corporate income tax (CIT) rate reduced to 25%The draft 2018 Finance Law would cut the French CIT, currently 33.1/3%, as follows:
• For tax years beginning on or after January 1, 2018, the standard CIT rate for all companies would be 28% on taxable income up to EUR 500,000 and 33.1/3% on taxable income exceeding this amount.
• For tax years beginning on or after January 1, 2019, the standard CIT rate for all companies would be 28% on taxable income up to EUR 500,000 and 31% on taxable income exceeding this amount.
• For tax years starting on or after January 1, 2020, the standard CIT rate for all companies would be 28%.
• For tax years starting on or after January 1, 2021, the standard CIT rate for all companies would be 26.5%.
• For tax years starting on or after January 1, 2022, the standard CIT rate would be 25% for all companies.
Temporary corporate surtax for large companies The French Parliament adopted the final version of the bill on November 14, 2017, and introduced two exceptional surtaxes on CIT for large companies. This could affect MNEs with French operations or subsidiaries.
The surtax applies only to tax years ending on or after December 31, 2017 through December 30, 2018.
The surtax has two components:
• For companies with revenue exceeding EUR 1bn: a 15% contribution (the ’exceptional’ contribution).
• For companies with revenue of at least EUR 3bn: an additional 15% contribution (the ’additional’ contribution).
The two contributions are assessed on the amount of corporation tax due for a given tax year before any tax relief or tax credit offset.
PwC observation:The surtax and the decrease in the French CIT rate now apply and MNEs operating in France should review their potential impact, especially with respect to their deferred tax on French earnings
Guillaume GlonParisT: +33 0 1 56 57 40 72E: [email protected]
Julie CopinParisT: +33 0 1 56 57 44 17E: [email protected]
Guilhem CalzasParisT: +33 0 1 56 57 15 40E: [email protected]
www.pwc.com/its
Slovakia
Slovakia introduces participation exemption
Recent changes to the Slovak Income Tax Act include the introduction of participation exemption rules. Capital gains on sales of shares in Slovak and foreign companies of selected legal forms may be exempt from CIT. This exemption, however, does not apply to taxpayers whose main activity is trading securities or to companies in liquidation, bankruptcy or restructuring.
The participation exemption may apply if the following conditions are met:
• gain on sale of shares does not arise earlier than 24 consecutive calendar months from the day the shareholder acquired at least 10% of the shares (such period starts on January 1, 2018, at the earliest); and
• the seller must meet the substance criteria in the Slovak territory. Thus, the seller will have to perform essential functions while having all related personal and material equipment, as well as managing and bearing risks related to ownership of the shares.
PwC observation:Due to transitory provisions in the Slovak Tax Act, the new participation exemption practically can be used in 2020.
Christiana SerugovaSlovakiaT: +421 903 2610 10E: [email protected]
Rastislava KrajcovicovaSlovakiaT: +421 903 268 040E: [email protected]
www.pwc.com/its
South Korea
Korean National Assembly approves tax law changes
The Korean National Assembly in December 2017, approved amendments to tax laws with some changes to the government’s proposals announced in August 2017. Details of the significant changes to the original proposals that impact Korean inbound investors from a CIT perspective are summarized below. Details of the original proposals were highlighted in PwC’s International Tax News, September 2017 edition.
• Increase in CIT rate for taxable income exceeding Korean won (KRW) 300 billion: The CIT rate will increase to 25% for taxable income exceeding KRW 300 billion instead of the proposed threshold of KRW 200 billion. The current tax rates applicable to taxable income of KRW 300 billion or less will remain unchanged.
• Limitation on utilization of tax losses: Currently, the amount of tax loss carryovers from prior years that can be utilized by a Korean entity other than SMEs are generally limited to 80% of current year taxable income. The 80% threshold will lower to 70% for fiscal years starting from January 1, 2018 and to 60% for fiscal years beginning January 1, 2019. The proposed thresholds initially were 60% and 50% for fiscal years beginning January 1, 2018 and 2019, respectively.
• Reduction in research and development (R&D) tax credits for large companies: Large companies currently can claim tax credits for qualifying R&D expenditure at a rate ranging from 1-3% of the current year expense or at 30% of the incremental R&D expenditure during the year that exceeds the average expenditure of the previous four years. As proposed, the R&D tax credit rate of 1-3% under the current year expense method would be reduced to 0-2%. Under the finalized bill, the tax credit rate under an incremental expense method, which was proposed to remain unchanged, would be reduced from 30% to 25%.
• Other key changes: The finalized bill introduces new rules to replace the existing tax on excess corporate earnings rules, limit interest expense deductions related to hybrid mismatch arrangements, and cap interest deductions. The interest cap rule is effective for fiscal years commencing on or after January 1, 2019 and limits net interest deductions for loans from overseas related parties to 30% of adjusted taxable income, with some exceptions for banking and insurance companies. These finalized rules are largely unchanged from the original proposals announced.
PwC observation:Most of the proposed changes are effective for fiscal periods starting on or after January 1, 2018. Therefore, MNEs in Korea should assess how these changes could impact them. Supporting details will be finalized in relevant Enforcement Decrees.
Alex Joong‑Hyun LeeSeoulT: +82 2 709 0598E: [email protected]
Sang‑do LeeSeoulT: +82 2 709 0288E: [email protected]
Robert BrowellSeoulT: +82 2 709 8896E: [email protected]
www.pwc.com/its
Turkey
New Conditions for utilizing CIT exemption for companies operating in Technology Development Zones
The Council of Minister’s October 19, 2017 Decision enacted new conditions for utilizing the CIT exemption. Corporations operating in Technology Development Zones may benefit from the CIT exemption for revenues from the sale, transfer, or lease of IP rights, if those rights are registered as patent, functionally patent equivalent documents or design registry in accordance with relevant legislation. This legislation will apply to profits from projects that begin on or after October 19, 2017 and profits that arise from ongoing projects after June 30, 2021.
When taking the average of the last five fiscal periods, if annual gross income from IP rights does not exceed 30 million New Turkish Lira (TRY) and the sum of annual net sales proceeds is less than 200 million TRY (group aggregation is taken into account if any group is involved), then profits arising from R&D and design activities may be exempt from CIT without a patent or patent equivalent document.
PwC observation:The regulation amends new conditions for using the CIT exemption, possibly decreasing incentive amounts for corporations. Moreover, for large scale international companies, in order to benefit from the exemption, project outcomes should be registered on behalf of a legal entity operating in Turkey. The applicable regulations for this change are expected to be published soon.
Özlem Elver KaraçetinTurkeyT: +90 212 326 64 56E: [email protected]
United Kingdom
UK enacts Finance Act and publishes draft Finance Bill
The UK Finance Act (No2) 2017 was enacted on November 16. This Act includes a number of measures (including clauses introducing corporate loss reform, corporate interest restriction, and the substantial shareholdings exemption) that were originally included in the last Finance Bill but subsequently dropped as the general election reduced the time available to debate that Bill. These measures were originally announced to be effective on April 1, 2017. That effective date has been retained in the amended clauses that have now been enacted.
• Hybrid mismatch rules - Some aspects of the corporation tax rules that apply to arrangements involving hybrid structures and instruments, will be amended to clarify how and when the rules apply so that the rules operate as intended.
• Interest deductibility restriction – The deadline for Public Benefit Infrastructure companies to elect the special regime is relaxed and other minor changes so that the rules operate as intended.
• Double Taxation Relief - From November 22, 2017 a restriction on the relief for foreign tax incurred by an overseas branch of a company where the company has already received relief overseas for the losses of the branch against profits
other than those of the branch is introduced. This should prevent the company from receiving t tax relief twice for the same loss. The Double Taxation Relief targeted anti-avoidance rule will also be amended to remove the requirement that HMRC issue a counteraction notice and to extend the scope, in order to ensure it is effective.
• Double taxation arrangement: multilateral instrument - With effect from the Royal Assent of the Finance (No. 2) Act 2017, the powers giving effect to double taxation arrangements will be amended to allow the implementation of the Multilateral Convention to Implement Tax Treaty Related Measures to prevent BEPS.
• Withholding tax (WHT) on royalties - Effective April 2019, WHT obligations will be extended to payments for royalties and certain other rights, made to low- or no-tax jurisdictions in connection with sales to UK customers. The rules will apply regardless of the payer’s location.
• Corporate capital gains - The government will amend the Substantial Shareholding Exemption legislation and the Share Reconstruction rules to avoid the triggering of unintended chargeable gains when a UK company incorporates foreign branch assets in exchange for shares in an overseas company.
• Intangible Fixed Asset regime - The government will consult in 2018 on the tax treatment of IP.
PwC observation:MNEs should review the enacted Finance Act and draft Finance bill to understand its impact.
Robin G PalmerLondonT: +44 20 7213 5696E: [email protected]
Sara‑Jane ToveyLondonT: +44 20 7212 2507E: [email protected]
www.pwc.com/its
United States
Proposed regulations ‘clarifying’ rules applicable to CFCs’ foreign currency transactions address many foreign currency traps for the unwary
On December 18, 2017, Treasury proposed regulations regarding foreign currency transactions that contain changes to the hedging and subpart F currency rules and introduced a foreign currency mark-to-market method of accounting. Taken together, the changes (many of which are clarifications) produce sensible, intuitive results with respect to foreign currency gains and losses realized by CFCs. These changes are welcome and evidence Treasury’s intention to have the regulations operate in a manner that produces a clear, intuitive and economically accurate result from a tax accounting and character standpoint. Importantly, many of these changes can be relied on starting December 19, 2017.
The participation exemption may apply if the following conditions are met:
Please see our PwC Insight for more detail.
David ShapiroWashingtonT: +1 202 414 1636E: [email protected]
Jeffrey MaddreyWashingtonT: +1 202 414 4350E: [email protected]
Rebecca LeeSan FranciscoT: +1 415 498 6271E: [email protected]
PwC observation:The foreign currency and hedging rules implicated are still relevant after fundamental tax reform. In fact, these rules may be even more important, as corporate treasurers reorganize their treasury functions in light of the sweeping changes to the international tax regime.
The changes eliminate many unintended traps for the unwary and should help organisations manage their foreign currency exposures. Companies should review and update current policies, procedures and tax hedging identification statements to avail themselves of the benefits in the proposed regulations and to prepare for their finalization.
www.pwc.com/its
AdministrativeBrazil
The Federal Brazilian tax authorities (RFB) published Normative Instruction 1,772/2017 on December 26, 2017, making certain amendments to the existing regulations on the requirements for claiming tax credits in Brazil for foreign taxes paid.
Normative Instruction SRF 213/2002 (NI SRF 213/2002) and Normative Instruction RFB 1.520/2014 (NI 1,520/2014) provide the requirements and conditions for claiming a credit for Brazilian CIT purposes (including both corporate income tax [IRPJ] and Social Contribution on Net Profits [CSLL]).
NI 1,772/2017 amends NI SRF 213/2002 to include alternatives that the tax collection voucher required to prove the tax paid be recognized by the Brazilian embassy in the local jurisdiction. The alternatives are:
• For jurisdictions that are signatories to the Convenção sobre a Eliminação da Exigência de Legalização de Documentos Públicos Estrangeiros’ (Convention on the Elimination of the Requirement of Legalisation of Foreign Public Documents), also referred to as the Apostille Convention, the official tax collection document should be certified/stamped by the appropriate designated authority and the stamped document provided along with a sworn translation into Portuguese, or
• The requirement may be waived where the taxpayer provides the entity’s corresponding financial statements along with proof that the local legislation envisages the income tax that was paid by way of the official collection document.
The first alternative regarding the Apostille Convention was also included in NI 1,520/2014, along with minor reporting clarifications.
The amendments became effective on December 26, 2017.
Fernando GiacobboSao PauloT: +55 11 3674 2582E: [email protected]
Mark ConomySao PauloT: +55 11 3674 2519E: [email protected]
PwC observation:Taxpayers currently taking credits for foreign taxes should revisit their internal processes to determine whether they are able to simplify the administrative processes in accordance with the RFB’s guidance.
www.pwc.com/its
EU/OECDCyprus
Cyprus’ public consultation on the EU’s anti-tax avoidance directives
The Cyprus tax authority (CTA) launched a public consultation on November 14, 2017 on Cyprus’ incorporating into national law the two EU Directives on anti-tax avoidance (ATAD I and ATAD II or collectively, ‘the ATADs’). This is the first step in implementing the ATADs.
The CTA published, in Greek, the draft bill text for implementing the ATAD’s minimum standard measures for: (i) interest expenses, (ii) exit taxation, (iii) CFCs, (iv) hybrid mismatches, and (v) a general anti-abuse rule (GAAR).
The draft bill provides effective dates for the proposals that are not earlier than what the ATADs require. The effective dates are, for the:
• interest limitation rule, CFC rule, and GAAR rule – January 1, 2019 • exit taxation provisions – January 1, 2020 • hybrid mismatch rules – January 1, 2020 (except for certain reverse
hybrid mismatch provisions, which are January 1, 2022)
We expect that final legislative proposals and the Cyprus Parliament vote will occur in the first half of 2018. Any formal legislative proposals may deviate substantially from the draft proposals explained below.
Interest limitation rule According to this rule, interest costs that would otherwise be deductible under the Cyprus income tax law are only deductible up to 30% of adjusted Cyprus taxable profit (i.e., taxable earnings before interest, tax, depreciation and amortization, or taxable EBITDA). This rule applies to the excess deductible interest expense, i.e., the amount by which
deductible interest expense exceeds the amount of taxable interest income. When a company is a member of a Cyprus group, it applies at the Cyprus group level. Otherwise, it applies per company. The rule has a 75% relationship condition and is referred to below as ‘the Cyprus taxpayer’.
Standalone companies (i.e., those that on a worldwide basis are not members of a group, have no associates, and no PEs) and financial institutions are excluded from the interest limitation rule. Also excluded from this rule are loans entered into before June 17, 2016, but subsequent amendments to those loans are not excluded In addition, the financing of certain public infrastructure projects and their associated income are excluded.
The interest limitation rule contains a 3 million Euro safe-harbor threshold. Furthermore, there is group ratio exception, which is based on the available equity at the Cyprus taxpayer level as compared to the available equity within the Cyprus taxpayer’s consolidated group for financial reporting purposes on a worldwide basis. If the ratio of ‘equity/total assets’ is higher at the Cyprus taxpayer level (or even up to 2% lower) as compared to its consolidated group on a worldwide basis, then the interest limitation rule, in effect, does not apply.
The draft bill also contains a carry forward rule so that non-deductible excessive interest costs may be carried forward for up to five years. This is in line with Cyprus’ five-year income tax loss carry forward rule.
Proposed measures regarding CFCsThe ATAD provides EU Member States with two different approaches to combat structures with CFCs. CFCs are low taxed (<50% of the domestic tax) foreign companies, directly or indirectly controlled by an EU Member State resident company.
In the first approach (Model A), passive income, such as interest, royalties and dividend income of a CFC is included as current income in a domestic
company’s taxable base and is taxed in accordance with domestic rules, unless the CFC is an EU/EEA resident involved in substantial economic activities. The second approach (Model B) is based on the arm’s length principle. This approach combats structures where income of a domestic company is allocated artificially to a CFC.
The draft bill follows the Model A approach. We expect that Model B will be explored during the consultation process.
Rules regarding exit taxation The draft bill provides for exit taxation where an asset leaves Cyprus’ taxing jurisdiction but remains under the same ownership (such as when a company transfers a taxable asset from its Cyprus head office to an exempt foreign PE). We expect that this rule will be limited in scope and apply only to those assets that are otherwise subject to Cyprus income tax. However, the draft bill does not clearly provide for this.
GAAR The draft bill includes the ATAD GAAR, which will allow the CTA to ignore non-genuine arrangements where one of the main purposes is to obtain a tax advantage that defeats the purpose of the tax provision. Arrangements are regarded as non-genuine to the extent they are not put into place for valid commercial reasons that reflect economic reality. We expect this rule to apply only to ‘wholly artificial arrangements’ as set out in the EU tax framework.
Hybrid mismatch rules The hybrid mismatch rules will capture many cases of cross-border double non-taxation that involve hybrid mismatches (i.e., differences in the characterization of an instrument, payment, PE or entity by different taxing jurisdictions).
Marios AndreouNicosiaT: +357 22 55 52 66E: [email protected]
Stelios ViolarisNicosiaT: +357 22 55 53 00E: [email protected]
Joanne TheodoridesNicosiaT: +357 22 55 36 94E: [email protected]
PwC observation:Taxpayers should follow developments relating to the ATADs in order to assess the impact on their business.
www.pwc.com/its
Thomas LooseNew YorkT: +(212) 671 8395E: [email protected]
Benjamin EngelNew YorkT: +646 471 5627E: [email protected]
Germany
CJEU finds that previous version of German anti-treaty/directive shopping rules violates EU law
In two judgments issued on December 20, 2017 (Deister Holding – C-504/16 and Juhler Holding – C 613/16), the Court of Justice of the European Union (CJEU) ruled that the previous version of the German anti-treaty/directive shopping rules in effect through 2011 does not comply with EU law.
The two judgments indicate that the CJEU also might find the current version of the rules do not align with EU law. The CJEU will have a chance to rule on the current rules in a pending case (C-440/17).
Please see our PwC Insight for more information.
PwC observation:Taxpayers should consider whether they can benefit from this decision and whether they should apply for WHT refunds before year-end.
www.pwc.com/its
Marios AndreouNicosiaT: +357 22 55 52 66 E: [email protected]
Stelios VolarisNicosiaT: +357 22 55 53 00 E: [email protected]
Joanne TheodoridesNicosiaT: +357 22 55 36 94 E: [email protected]
Cyprus-Ethiopia tax treaty enters into force
The first tax treaty between Cyprus and Ethiopia entered into force on October 18, 2017. The treaty took effect on January 1, 2018 for Cyprus and will take effect for Ethiopia on July 8, 2018.
The treaty provides for a 5% WHT rate on dividend, interest, and royalty payments. There is an exemption for interest that is beneficially owned by the government, a political subdivision, local authority, or the National Bank of the recipient State.
Despite the WHT rates, Cyprus does not impose WHT on payments of dividends and interest to non-residents of Cyprus at all times, and on payments of royalties to non-residents of Cyprus under conditions, in accordance with the Cyprus domestic tax legislation.
Per the treaty’s terms, Cyprus retains the exclusive taxing rights on disposals by Cyprus tax residents of shares in Ethiopian companies, including Ethiopian companies holding Ethiopia-located immovable property.
TreatiesCyprus
PwC observation:This treaty further expands the Cyprus treaty network and opens the way for new investment opportunities and trade relations between the two parties.
www.pwc.com/its
Hong Kong
Tax treaties with Belarus, Latvia and Pakistan enter into force
The Hong Kong Inland Revenue Department (HKIRD) recently announced that the tax treaties signed by Hong Kong with Latvia and Pakistan entered into force on November 24, 2017. The treaty with Belarus entered into force on November 30, 2017.
They will become effective from year of assessment 2018/19 in Hong Kong. The Hong Kong-Belarus and Hong Kong-Latvia tax treaties became effective in Belarus and Latvia on January 1, 2018. The Hong Kong-Pakistan treaty will become effective in Pakistan on July 1, 2018.
Paraguay / Uruguay
Paraguay and Uruguay sign tax treaty
On September 8, 2017 tThe Paraguayan and Uruguayan governments signed a tax treaty and an Agreement for the Exchange of Information (AEoI), which substantially follow the OECD Model Tax Convention. We expect the treaty to enter into force in 2018 provided Congressional approval in both countries and the exchange of ratifying notes occur in 2018.
The agreement defines the tax rate limit applicable to some activities.
The Agreement also defines which taxes and persons are in its scope, and foresees the mechanism to avoid double taxation, taking the option of the credit concession (with the limitation of the tax that the source country applied on such income or assets).
Regarding the AEoI, the treaty includes specific clauses and establishes a procedure for mutual assistance in collecting taxes.
Fergus WT WongHong KongT: +852 2289 5818 E: [email protected]
Juan TellecheaAsunciónT: +595 21 418 8000 E: [email protected]
Nathalia Rivas PetrisAsunciónT: +595 21 418 8304 E: [email protected]
PwC observation:Given that Hong Kong does not currently impose any WHT on dividends and interest paid to non-residents and the WHT rate on royalties under the Hong Kong domestic law (4.95%) is lower than those under the Hong Kong-Belarus (5%) and Hong Kong-Pakistan (10%) treaties, the Hong Kong-Latvia treaty is relatively more favorable. The WHT rate will be reduced to 0% (for royalties paid by a Latvian-resident company to a Hong Kong-resident company that is the beneficial owner of the royalties) or 3%.
The major benefit of these tax treaties for these countries’ resident companies investing in Hong Kong is the protection against Hong Kong profits’ tax exposure, as long as their business activities do not create a PE in Hong Kong.
PwC observation:Given the economic growth in Paraguay and Uruguay, the implementation of this tax treaty and the AEoI could be a great opportunity for investment in both countries. In addition, there are many Uruguayan investors in Paraguay.
This is one of the new fiscal transparency guidelines adopted by the Paraguayan government in order to align to OECD rules and offer greater international competitiveness.
www.pwc.com/its
Singapore
Treaty updates
The Singapore tax authorities (IRAS) on October 11, 2017, issued a new circular which provides an overview of the application of Singapore’s treaties and the mutual agreement procedure (MAP) under Singapore’s treaties.
Country-by-country (CbC) reporting The IRAS on October 16, 2017, published a list of jurisdictions with which Singapore has established bilateral AEoI relationships under the Multilateral Competent Authority Agreement on the Exchange of CbC Reports. CbC reports submitted to the IRAS will be provided to the tax authorities of these jurisdictions.
Tax treaty with India The Third Protocol to the India-Singapore treaty inserts Article 9(2), thus enabling taxpayers to settle transfer pricing disputes through Bilateral Advance Pricing Agreements (BAPAs) and MAPs. The IRAS has introduced transitional procedures on issues such as the first covered period and roll-back period for BAPAs, conversion of unilateral APAs to BAPAs (and alignment of financial periods), and clarification on filing MAPs.
PwC observation:These updates provide greater clarity on the application of Singapore’s treaties and the relevant administrative procedures.
Chris WooSingaporeT: +65 6236 3388 E: [email protected]
Paul LauSingaporeT: +65 6236 3388 E: [email protected]
Paul CorneliusSingaporeT: +65 6236 3388 E: [email protected]
www.pwc.com/its
Acronym Definition
APA Advance pricing agreement
ATAD Anti-tax avoidance directive
BEPS Base erosion and profit shifting
CbC Country-by-country reporting
CFC Controlled foreign company
CIT Corporate income tax
CJEU Court of Justice of the European Union
CTA Cyprus tax authority
EBITDA Earnings before interest, taxes, depreciation and Amortization
EEA European economic area
EoI Exchange of information
EU European Union
GAAR General anti-abuse rule
HKIRD Hong Kong Inland Revenue Department
HMRC Her Majesty’s Revenue and Customs
IP Intellectual property
Acronym Definition
IRAS Singapore tax authorities
KRW South Korean won
MAP Mutual agreement procedure
MNCs/MNEs Multinational corporations/enterprises
MS Member state
OECD Organization for Economic Co-operation and Development
PE Permanent establishment
R&D Research and development
RFB Federal Brazilian tax authorities
SME Small and medium-sized enterprises
TRY New Turkish Lira
UK United Kingdom
US United States
VAT Value added tax
WHT Withholding tax
Glossary
www.pwc.com/its
Contact us
For your global contact and more information on PwC’s international tax services, please contact:
Shi-Chieh ‘Suchi’ Lee Global Leader International Tax Services Network
T: +1 646 471 5315 E: [email protected]
Geoff JacobiInternational Tax Services
T: +1 202 414 1390E: [email protected]
www.pwc.com/its
At PwC, our purpose is to build trust in society and solve important problems. We’re a network of firms in 157 countries with more than 223,000 people who are committed to delivering quality in assurance, advisory and tax services. Find out more and tell us what matters to you by visiting us at www.pwc.com.
This content is for general information purposes only, and should not be used as a substitute for consultation with professional advisors.
© 2018 PwC. All rights reserved. “PwC” refers to the PwC network and/or one or more of its member firms, each of which is a separate legal entity. Please see www.pwc.com/structure for further details.
Design Services 31110 (01/18).
