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October 2018

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  • Sponsored by KPMG China
    At an executive meeting of China's State Council on July 23 2018, Premier Li Keqiang announced that the country would expand the scope of the 75% corporate income tax (CIT) super deduction for eligible research and development (R&D) expenses to cover all resident enterprises. This super deduction rate currently applies to defined science and technology-related small and medium-sized enterprises (SMEs), while other enterprises can obtain a 50% super deduction. The announced changes will abolish the 50% super deduction incentive. The details of the expanded incentive are still pending, and it remains to be seen whether the increased super deduction rate can be applied retroactively and whether the scope of deductible expenses will be expanded further. This improvement to the super deduction follows the enhancement of the incentive in June's Cai Shui (Circular) 64, to cover R&D work outsourced by Chinese enterprises to foreign providers.
  • Sponsored by Eurofast Croatia
    Tax incentives in Croatia for research and development (R&D) projects were granted between 2007 and 2014 based on Articles 111 a. to 111 f. of the Act on Scientific Activity and Higher Education. However, the European Union issued Commission Regulation (EU) No. 651/2014 in June 2014, concerning certain categories of state aid; this used significantly different terminology, definitions, and requirements, and rendered the abovementioned articles invalid. Croatian entrepreneurs found themselves in something of a vacuum for more than three years, awaiting a new legal framework for R&D incentives, as the relevant tax incentive had been abolished on January 1 2015. In July 2018, the Croatian Parliament adopted and published the Act on State Aid for Research and Development Projects, which the government had submitted in January 2018.
  • Sponsored by Hager & Partners
    In general terms, inherence can be described as the relationship between the cost and the enterprise, where the cost has a specific relevance to the determination of income; this is a result of its connection not to a specific revenue, but rather to an activity potentially able to produce income. Based on this assumption, in order to consider a cost deductible (i.e. inherent), the taxpayer is required to demonstrate clearly the connection with the activity, providing the tax authority with "sufficient" documentation.
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