Monday, 12 June 2023 05:49

1st Quarter Issue Of 2023 PRISM -2023PRISM

PRISM Tax Newsletter
1st Quarter 2023 issue
The latest PRISM, the quarterly-issued Reanda international tax newsletter, provides updates and insights about the recent international taxation changes and topical issues. Please click here to read more:
Read the publication

利安达国际最新一期税务季刊,让您掌握最新的国际税务动态与热门话题。 欢迎点击以下链接阅读!
焦点内容 Highlights ​



Proof of Submission of Return (PSR) u/s 184A Finance Act 2022 (Bangladesh)
A major change has been made in requirement to furnish a proof of filing income tax return through section 184A in the Finance Act 2022 substituting the said section of previous year 2021. The substituted section of law is titled as 'proof of submission of return (PSR) required in certain cases' while in the previous year 2021 the title was 'requirement of 12 digits Taxpayers Identification Number (TIN) in certain cases.
This provision of law has been made mandatory for 38 kinds of services wherein a person responsible for providing any said services shall not provide the service unless a proof of submission of return is furnished before him by the taxpayer.

2022 年财政法第 184A 条取代前一年 2021 年的相关条例部分,按此提交所得税申报表证明的要求出现了重大更改。在前一年 2021 年,条例名为 “在某些个案下提供12 位数纳税人识别号 (TIN)”的相关要求 ,被取代为 “在某些个案下,提交申报表证明(PSR)的相关要求。



A New Foreign Exchange Mark in Brazil
Since the Getúlio Vargas Government (1933), it was only in late 2022 that several resolutions of the Brazilian Monetary Board (CMN) and the Brazilian Central Bank (BACEN) were updated containing the new norms on foreign exchange and international capital (foreign capital in Brazil and Brazilian capital abroad), so as to regulate Act No. 14.286/2021, which corresponds to the New Foreign Exchange Mark in Brazil.



Updated Cyprus Tax Incentives for first employment in Cyprus
On 26 July 2022, the House of Representatives in Cyprus voted amendments (under Article 8(23A) of tax regulations and incentives for the first employment income under certain conditions.

Strong economic momentum in 2023
The Greek economy remains resilient even in 2023, when recession or zero growth is predicted in the Eurozone. Although the growth rate will be much lower than the 6% that is expected to close in 2022 but even the adverse scenario predicts growth of 1.6% for 2023. Equally important as growth is the prospect of the Greek economy returning to primary surpluses. The positive forecasts were based on two main factors. Firstly, the increase in investments through the action of the Recovery and Resilience Fund and secondly, the stimulation of exports. The fiscal support measures incorporated in the 2023 budget also contribute positively.

GST on Secondment in India
The secondment between several entities within a Multinational group is a common feature. Secondment poses several complex tax and legal issues in several jurisdictions and India is no different. The recent blow is the applicability of the Goods and Services Tax (GST).
The Hon’ble Supreme Court of India gave a verdict last year that the employees working under secondment arrangements cannot be considered actual employees of the secondee (Indian) company. Instead, the foreign entity that seconded the employees continues to qualify as their employer, and the arrangement between the two entities is in the nature of "manpower recruitment or supply agency service," leviable to Service Tax under the erstwhile Service tax law replaced by GST in 2017. Due to the same kinds of provisions, the judgment is equally applicable to the present GST regime as well.


Italian 2023 Budget Law
The 2023 Budget Law, Law no. 197 of 29 December 2022, published in official gazette no. 303 on 29 December 2022, and effective 1st January 2023, introduced several tax measures that may be of interest to multinational enterprises with Italian operations, including:
- Limited deduction of costs incurred with black-listed jurisdictions
-Transition tax on undistributed profits from low-tax subsidiaries
-Step-up of Italian participations held by nonresident entities
-Permanent establishment exemption for investment management activities
-One-off energy windfall tax

2023 年预算法,即2022 年 12 月 29 日第 197 号法律,刊登在官方公报第303号,于2023 年 1 月 1 日生效,该法引入了一些可能对在意大利开展业务的跨国企业感兴趣的税收措施,包括:

Budget 2023 Retabled On 24 February 2023
On 24 February 2023, the Prime Minister and Finance Minister of Malaysia, YAB Dato’ Seri Anwar Ibrahim announced Budget 2023 (Retabled) themed “Developing Malaysia MADANI”. This Budget reflects the principles of accountability and pure value system that can address the current challenges including the highly uncertain global economic challenge.


Digital Service Tax in Nepal
Nepal introduced a 2% digital service tax for non-resident (foreign) digital service providers (services include Advertisement, Data storage service, Cloud service, Gaming, E-Commerce, and Other Similar Services) having annual transactions above NPR 2 million (approximately USD 15,500). Non-residents must apply to the Nepalese tax authorities for registration within 30 days of crossing the transaction threshold, file their return to the office online, and pay their taxes within three months after the end of the tax year (mid-July). In the event of a delay, annual fee of 0.1% annually and interest of 15% will be assessed.


Highlights of Nigeria’s 2023 Budget
President Muhammadu Buhari signed the 2023 Appropriation Bill into law on the 3rd of January, 2023. The 2023 budget is the final budget of President Muhammadu Buhari’s administration. The budget has been termed “Budget of Fiscal Consolidation and Transition”.

穆罕默杜·布哈里总统于 2023 年 1 月 3 日签署了 2023 年拨款法案成为法律。 2023 年预算是穆罕默杜·布哈里总统政府在任的最终预算。该预算被称为“财政整合和过渡预算”。

Tax on Deemed Income from Immovable Property (Section 7E)
From tax year 2022 and onwards, tax has been levied under section 7E of the Income Tax Ordinance, 2001 at the rate 20% on deemed rental income computed as 5% of the Fair Market Value of immovable properties situated in Pakistan. The fair market value is to be determined under section 68 of the Income Tax Ordinance, 2021. Whereas some immovable properties have been excluded from the calculation of deemed income under 7E of the Ordinance.

从2022纳税年度起,根据2001年《所得税条例》第7E节的规定,对视为租金收入征收20% 的税款,租金收入按巴基斯坦的不动产的公平市场价值的5%计算。公平市场价值将根据2001年《所得税条例》第68条定立。而根据该条例第7E节,一些不动产财产已被排除在本条例第7E条规定的认定收入计算范围之外。


Saudi Arabia
Transfer pricing
Transfer pricing is defined as the pricing of transactions between related persons or persons under common control (“Controlled Transactions”). The importance of Transfer Pricing Bylaws lies in the necessity to implement and enforce the Arm’s Length Principle on transactions between related persons or persons under common control as if they were conducted between independent persons.
It applies several methods in pricing transactions:
1- Independent price method
2- Resale price method
3- Total cost method plus profit margin
4- Net Profit Margin Method for Transaction
5- Profit division method
Many factors must be taken to choose between these methods, and the parties must submit the required documents from the Zakat, Tax, and Customs Authority.

5- 利润分配法

Increase in GST rate and GST related crimes
Goods and Services Tax (GST) is a consumption tax levied on the import of goods and almost all supplies of goods and services in Singapore. A business must register for GST when the taxable turnover exceeds S$1 million, with certain exceptions. The GST rate has been increased from 7% to 8% on 1 January 2023 and will be increased to 9% on 1 January 2024. The Inland Revenue of Authority of Singapore (IRAS) conducts regular audits to ensure tax compliance by individuals and businesses as there are cases of non-compliance and GST evasion.

商品和服务税是针对进口商品和在新加坡供应商品和服务征收的消费税。当应税营业额超过100万新元时,企业必须成为消费税注册公司,但有某些例外。消费税从2023年1月1日起从7%提高到8%,并将于2024年1月1日起提高到9%。 因存在不合规和逃避消费税的情况,新加坡国内税务局定期进行审计以确保个人和企业遵循税务规定。

New Promotion Strategy in Thailand 2023 – 2027
Thailand's Board of Investment (BOI) has issued a new investment promotion strategy for the next five years (2023–2027) which effected in January 2023. Replacing the BOI's current eight-year scheme (2015–2022).

2023 - 2027年泰国推出新推广战略


National Insurance and the State Pension
Pensions are often in the press, but the UK State Pension and how it is earned is often overlooked and many UK/expatriates approaching State Pension age realise that they have not made sufficient contributions to be entitled to the full State Pension.