Author: Laura Pakarinen
> Law proposal for TV tax presented to the parliament.
> Law proposal limiting interest deduction published.
> Law proposal for TV tax presented to the parliament.
(Reviewed up tp 9 May 2012)
Country Surveys
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Finland
RomaniaGuineaAuthor: Albert Atangana
> Deduction of intermediate input increased from 20% to 50% for companies under regime C.
> Minimum lump-sum tax.
> Changes to the surface royalties rates for mining activities.
> Withholding tax on royalties increased from 10% to 15%.
> Withholding tax on management fees and technical service fees increased from 10% to 15%.
> Withholding tax on royalties increased from 10% to 15%.
(Reviewed up to 1 May 2012)CyprusAuthor: Antonis Taliotis
> Standard rate of VAT increased to 17%.
> Supply of construction services subject to zero rate.
(Reviewed up to 15 April 2012)
DjiboutiMauritaniaPalestinian Autonomous AreasUnited Arab EmiratesAuthor: Salah Gueydi
> Updated treaty chart.
> New law on foreign ownership of companies.
(Reviewed up to 1 April 2012)KuwaitAuthor: Salah Gueydi
> Treaty chart updated.
> Clarification to the Gulf Cooperation Council economic agreement.
(Reviewed up to 1 April 2012)KenyaAuthor: Fredrick Omondi
> Individuals whose income consists solely of employment income are no longer required to submit income tax returns.
> Maximum amount of deductible mortgage interest reduced from KES 180,000 to KES 150,000 per annum.
> Non-citizens can now only own land on a 99-year leasehold.
(Reviewed up to 20 March 2012)ZambiaAuthor: Kennedy Munyandi
> Reduction of corporate income tax rate on farming and banking.
> Introduction of a final WHT on commissions paid to non-residents.
> Change taxable period (tax year).
> Introduction of a new personal income tax table.
> Addition of new sectors to the priority sector list.
(Reviewed up to 14 March 2012)BoliviaAuthor: Lydia Ogazón
> New additional income tax on financial institutions.
> Introduction of the "solve et repete" instrument
> Payment or acquisition of goods or services exceeding BOB 50,000 must be documented with "reliable means of payment”.> Losses may be carried forward for 3 tax years (previously, losses could be carried forward indefinitely). Introduction of other restrictions for financial institutions, new productive companies and oil and mining companies.
> Losses may not be updated due to inflationary effects(Reviewed up to 1 March 2012)ChileAuthor: Carlos Gutiérrez
> Treaty between Chile and Russia enters into force.
(Reviewed up to 1 March 2012)
EgyptAuthor: Ridha Hamzaoui
> Reductions for early payments of tax debts introduced.
> Social security maximum base increased for employers.
> New real estate tax law enters into force.
> Clarification to capital gains tax regime.
> Social security maximum base increased for employees.
> New real estate tax law enters into force.
(Reviewed up to 1 March 2012)GabonAuthor: Albert Atangana
> New categories of exempt income.
> Incentives introduced for wood industry.
> Incentives introduced for cement industry.
> Dividends distributed by companies operating in the cement industry.
> Interests paid by companies operating in the cement industry.
> New VAT exemption introduced.
> Reduced 5% VAT rate introduced.
> Changes to capital duty.
> Exemption introduced for income derived by industrial and commercial profits.
> Dividends and interests paid by companies operating in the cement industry.(Reviewed up to 1 March 2012)MauritiusAuthor: Ridha Hamzaoui
> Tax regime for protected cell companies introduced.
> Double deduction for tourism companies and export-oriented companies abolished.
> Solidarity levy applicable for profits realized in 2012 and 2013.
> Clarification to withholding tax rates on payments to resident companies.
> Freeport companies’ exemption extended for an indefinite period.
> Capital gains tax abolished on immovable properties located in Mauritius.
> Withholding tax regime of payments to non-resident clarified.
> Tax treaties chart updated.
> Changes to the evaluation of fringe benefits.
> Solidarity income tax abolished.
> Capital gains tax abolished on immovable properties located in Mauritius.
> Deductions increased.
> Exemption threshold increased for employment income earned by non-residents.
(Reviewed up to 1 March 2012)TunisiaAuthor: Ridha Hamzaoui
> Capital gains exemption abolished for closed-end investment companies.
> Deductibility of certain provisions allowed to financial institutions.
> Exemption for export-oriented companies extended.
> Exemption for companies established in economic activity parks extended.
> Tax incentives introduced for Islamic financial instruments.
> Capital gains tax regime amended for non-resident companies.
> Tax on contracts concluded with foreign artists introduced.
> Capital gains tax regime amended for non-resident individuals.
(Reviewed up to 1 March 2012)LebanonAuthor: Ridha Hamzaoui
> Changes expected to be introduced by Budget 2012.> Changes to withholding tax regime expected to be introduced.
> Changes to dividends withholding tax regime expected to be introduced.
> Changes to interest withholding tax regime expected to be introduced.
> Tax treaties chart updated.
> VAT rate expected to be increased.
> Changes expected to be introduced by Budget 2012.> Changes to tax allowance regime.
(Reviewed up to 1 March 2012)NigeriaAuthor: Kennedy Munyandi
> Revision of payroll tax threshold.
> Introduction of a new personal income tax table.
> Revision of personal allowances.
(Reviewed up to 29 February 2012)Cape VerdeAuthor: Vanessa Arruda Ferreira
> New incentive for income from bonds.
> New rates for excise duties.
> New exempt income.
> New allowance amounts.
> New brackets at the income tax rate table.
> New withholding tax rates on wages.
> New withholding tax rates on income from business and professional services.> New International Business Centre.
(Reviewed up to 28 February 2012)BrazilAuthors: Fernando Tonnani and Bruno Gomes
> New rules for the SIMPLES regime.
> New incentives.
> New regime for social security contribution for specific business sectors.> Several changes on the IOF rates applicable to certain operations and introduction of IOF on transactions involving currency structured derivatives.
> New limit for exemption on pension income.
> New limits for deductions, allowances and credits.
> New brackets in the individual income tax table.
> New brackets for social security contribution.
> Creation of Individual Limited Liability Companies.
> New antitrust law.
(Reviewed up to 15 February 2012)OmanAuthor: Salah Gueydi
> Conditions to enjoy certain exemptions clarified.
> New conditions for deductibility of business expenses.> Tax compliance rules relaxed for small and medium-size enterprises.
> Conditions for agency PE clarified.
> New tax treaties in force.
> New rules on the interest deduction.
> New tax compliance requirements for foreign consultants carrying on activities in Oman.
(Reviewed up to 1 February 2012)QatarAuthor: Salah Gueydi
> New depreciation method introduced.
> New rules for Banks and insurance companies.
> Clarification of withholding tax rules applicable on contracts with non-residents companies.
> New tax treaties in force.
(Reviewed up to 1 February 2012)Saudi ArabiaAuthor: Salah Gueydi
> Clarification to the evaluation of inventory.
> Clarification for tax incentives schemes.
> New tax treaties in force.
(Reviewed up to 1 February 2012)SudanAuthor: Abdelgader A. Osman
> Increased corporate income tax rate for telecom companies.
> Social development tax increased.
> New treaties in force.
> Increased VAT rate for telecom companies.
(Reviewed up to 1 February 2012)South AfricaAuthor: Johann Hattingh
> Introduction of a withholding tax on dividends paid to non-resident companies.
> Abolishment of secondary tax on companies.
> Introduction of a dividend withholding tax.
> Introduction of a new Companies Act.
(Reviewed up to 31 January 2012)BurundiAuthor: Felix Buma, updated by Anapaula Trindade Marinho
> New country survey.
(Reviewed up to 1 January 2012)Congo (Dem. Rep.)Author: Farid Hasnaoui, updated by Lambert Ablet
> Clarification to withholding tax regime on dividends.> Clarification to withholding tax regime on interests.
> New VAT law introduced.
(Reviewed up to 1 January 2012)Costa RicaIsraelAuthor: Henriette Fuchs
> Capital gains tax regime amended.
> Corporate income tax rate increased.
> Withholding tax rates on interest and royalties payments increased.
> Tax regime for oil and gas companies amended.
> Income bands for social security contribution purposes amended.
> Withholding tax rates amended.
> Tax treaties chart updated.> Employment income tax rules amended.
> Changes to credit point system.
> Changes to income tax rates.
> Changes to withholding tax rates.
> Social security base and rates amended.
(Reviewed up to 1 January 2012)MadagascarAuthor: Albert Atangana
> Lower corporate income tax rate.
> Lower tax rate on income from movable capital.
> New relief for investments in renewable energy sources.
> Withholding tax rate on interest reduced.
> New exemptions introduced for VAT purposes.
> Lower tax rate on capital gains from immovable property.
> Lower personal income tax rate.
> Lower tax rate on income from movable capital.
> Withholding tax on interest reduced.
(Reviewed up to 1 January 2012)SeychellesAuthors: Malika Jivan and Felix Buma. Updated by Anapaula Trindade Marinho.> Completely rewritten survey.
(Reviewed up to 1 January 2012)JordanEthiopiaMozambiqueAuthors: Corporate and Individual Taxation: Vanessa Arruda Ferreira; Business and Investment: Patricia Dias de Almeida
> The ZFIL free zone is no longer operating.
> Tax treaties in force with Botswana, India and Vietnam.
> New withholding tax rates (advance payment) on employment income and pension income.
> The minimum capital is no longer required for private limited liability companies.
(Reviewed up to 1 November 2011)MexicoAuthors: Mariana Eguiarte Morett and Ricardo León Santacruz
> Comprehensive review.
(Reviewed up to 24 October 2011)PanamaAuthor: Andrea Marusic
> New tax treaties in force (Luxembourg and Qatar).
(Reviewed up to 15 October 2011)St. LuciaAuthor: The chapter is updated by Emily Fett.
> 2011/12 Budget amendments.
(Reviewed up to 1 October 2011)LiberiaAuthor: Theophilus Dekonty Joseph
> Corporate tax rate decreased from 35% to 25%.
(Reviewed up to 1 October 2011)AngolaAuthor: Vanessa Arruda Ferreira
> Clarification to exempt income.
> New tax incentives schemes introduced.
> Clarification to the real estate tax.
> Clarification of the tax regime of foreign-source income.
> New transfer tax regime on immovable property.
> Individuals exempt from earned income tax.
> Reduced withholding tax rates for dividends and interests.
> Withholding tax regime of various remunerations received by individuals.
> Additional remuneration subject to social security contributions.
(Reviewed up to 15 August 2011)CongoMoroccoAuthor: Laila Benchekroun
> Changes in social security contributions rates.
> New tax treaty in force with Greece.
(Reviewed up to 4 July 2011)BeninAuthor: Albert Atangana
> Changes to types of exempt income.
> New cap on the depreciation of tourism vehicles.
> Changes to dividend withholding tax regime.
> New tax incentives schemes introduced.
> New intercorporate dividends tax regime.
> New regime for foreign-source dividends and interests.
> New outbound dividends withholding tax regime.
> New solidarity tax introduced on flight tickets.
> New tax rate for directors’ remuneration.
> New progressive income tax rates and bands.
> New withholding tax rates for dividends and interests.
> New rules on deductibility of social security contributions.
> New inheritance and gift tax rates.
> Clarification of tax rates applicable to non-resident individuals on passive income.
(Reviewed up to 1 July 2011)Sao Tome and PrincipeAuthor: Sandra Martinho Fernandes
> Special regime introduced for oil companies.
> Tax treatment of losses incurred by oil companies.
> Increased corporate tax rate for oil companies.
> Exemption of dividends distributed by oil companies.
> Clarification to the source rules under São Tomé and Príncipe tax law.
> Exemption of dividends distributed by oil companies to non-resident corporate shareholders.
> Exemption of dividends distributed by oil companies to resident individuals.
> Capital gains on shares of oil companies.
> Exemption of dividends distributed by oil companies to non-resident individuals.
(Reviewed up to 1 July 2011)United Arab EmiratesAuthor: Salah Gueydi
> List of effective DTAs updated.
> New Company Law expected by end 2011.
> Agency Law amended with the effect to establish a committee to deal with agency disputes.
> List of restricted activities for foreigners updated.
> Conditions required for employment change (i.e. to move from one employment to another in the UAE) relaxed.
(Reviewed up to 1 July 2011)TogoAuthor: Albert Atangana
> Tax treatment of partnerships revised.
> More flexible conditions to deduct inter-corporate interest.
> Declining balance depreciation method introduced.
> Corporate income tax rates reduced.
> Standard withholding tax rate on dividends distributions reduced.
> New incentives for investments over USD 150 millions.
> New incentives for services linked to the financial markets.
> Power of investigation of the tax administration reinforced.
> One-stop shop established.
> Lower personal income tax rates.
> New exemptions on income from collective investment vehicles.
> Banking and Credit Unions Acts replaced.
(Reviewed up to 30 June 2011)Guinea-BissauAuthor: Sandra Martinho Fernandes
> Clarification on advanced levy on imports and exports.
> Changes to investment incentives schemes.
> Sales tax rate increased.
> Clarification on Tourism Tax.
> Changes to Inheritance and Gift Taxes.
(Reviewed up to 1 June 2011)LesothoAuthor: Chiara Bardini
> Clarification to tax rate applicable on export-oriented companies.
> Changes to income tax rates and bands.
> Clarification of tax rates applicable to non-resident individuals.
(Reviewed up to 1 June 2011)KenyaAuthor: Fredrick Omondi
> Deemed interest payment on interest-free loans.
> Increase in farm works capital deduction rate.
> Kenya–France tax treaty in force.
> Additional VAT-exempt supplies.
> Advance tax abolished.
(Reviewed up to 15 May 2011)
Sierra LeoneAuthor: Buffy Bailor
> Reduction in mining corporate tax rate.
> Introduction of new tax incentives.
> Reduction in customs duty rate on raw materials.
> Reduction in customs duty rate on raw materials.
(Reviewed up to 18 April 2011)
ZimbabweAuthor: Kennedy Munyandi
> Increase in mineral royalty rates on diamonds, platinum and gold.
> Fiscalized electronic tax registers zero-rated for VAT purposes.
> General reduction in customs duty rates.
> Income tax exempt threshold increased.
> Increase in exempt bonus payment.
(Reviewed up to 14 April 2011)ArubaAuthor: René Offermanns
> Reintroduction of an investment allowance.
> Introduction of a tax-free inflation allowance.
> Introduction of a limited liability company.
(Reviewed up to 1 April 2011)BahrainAuthor: Salah Gueydi
> Social security contributions rates increased.
> New tax treaties in force.
> Social security contributions rates increased.
(Reviewed up to 1 April 2011)
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