DTA between Ecuador and Japan enters into force
On 28 December 2019, the Double Taxation Agreement (DTA) between Ecuador and Japan was entered into force and applies from 1 January 2020. The DTA contains Dividends rate 5%, Interest rate 10%, and Royalties rate
See MoreAustria releases digital services tax guide
On 20 December 2019, Finance Ministry published guide regarding digital service tax. Under the guide, 5% tax will be applicable for advertisements on a digital interface. Accordingly, this guide helps to know of how to submit or payment digital
See MoreKazakhstan: State Revenue Committee clarifies statute of limitation for tax violations
Recently, the State Revenue Committee (SRC) described that the statute of limitations period in case of tax violations is 3 years instead of 5 years as from 1 January 2020. Before 1st January 2020, however, the statute of limitation period remains
See MoreEcuador: President made objections on second tax reform bill
On 14 December 2019, the President, Moreno, made objections on the second tax reform bill approved by the National Assembly. Accordingly, he proposed to limit the application of the thin-capitalization rules to inter-company loans. Accordingly,
See MorePanama extends CbC reporting deadline and notification
On 27 December 2019, Directorate General of Revenue of Panama has issued Resolution No. 201-9116 and 201-9117, with effect from the date of publication. Resolution No. 201-9116 extends the filing of Country by Country (CbC) reporting until 31
See MoreWTO: Discussions on Investment Facilitation for Development
A meeting of the WTO’s Structured Discussions on Investment Facilitation for Development took place on 12 December 2019. The initiative was launched two years ago and WTO members aim to make progress on this issue before the 12th Ministerial
See MoreUkraine: National Bank reduces the interest rate from December 2019
On 12 December 2019, the National Bank of Ukraine decided to reduce its key policy rate from 15.5% to 13.5% per annum with effect from 13 December 2019. The interest rate has a tax effect on the late tax payment interest and
See MoreMalaysia: IRB releases Transfer Pricing audit framework for 2019
On 15 December 2019, the Malaysian Inland Revenue Board (“MIRB”) published the TP audit framework (2019). The Transfer Pricing Audit Framework 2019 is effective from 15 December 2019 and replaces the Transfer Pricing Audit Framework 2013 which
See MoreLuxembourg implements EU ATAD 2 anti-hybrid measures
On 19 December 2019, the Luxembourg Parliament approved draft law implementing EU Anti-Tax Avoidance Directive (2017/952) (ATAD 2) into Luxembourg domestic law. ATAD 2 amends the EU Directive 2016/1164 which applies to mismatches between EU member
See MoreVietnam: MOF publishes draft Decree on deductible interest expenses
On 12 December 2019, the Vietnam Ministry of Finance (MOF) has published the draft Decree amending and supplementing Clause 3, Article 8 of Decree 20/2017/ND-CP to regulated approach on determining the deductibility for interest expense for
See MoreQatar publishes new regulations to amend income tax law
On 11 December 2019, Qatar published Executive regulations 39/2019 in the Official Gazette, introduced new Income Tax Law No. 24 of 2018. The new regulations are generally effective from 12 December 2019. Key features of the new regulations
See MoreOECD: Peer review reports on exchange of information on tax rulings
On 23 December 2019 the OECD released the 2018 peer review reports on the exchange of information on tax rulings. The reports cover implementation of the minimum standard under action 5 of the OECD action plan on base erosion and profit shifting
See MoreCosta Rica: Ministry of Finance publishes draft resolution on APA guidelines
In December 2019, the Costa Rican Ministry of Finance released a draft resolution regarding the procedures for processing advance pricing agreements (APAs). The draft guidelines state that APA applications would need to be addressed to the
See MoreArgentina: Tax Authority publishes Law 27541 for implementing tax reform 2020
On 23rd December 2019, Argentina published Law 27541 regarding Social Solidarity and Productive Reactivation in the Official Gazette, which contains measures on corporate income tax, personal income tax, dividend withholding tax etc. The Law was
See MoreGermany gazettes a law implementing EU directive on tax dispute resolution mechanism
On 12 December 2019, the German Official Gazette published a law implementing EU directive on tax dispute resolution providing a uniform mechanism to address tax treaty disputes among EU member states that meets the BEPS Action 14 minimum
See MoreGermany: Federal Ministry of Finance publishes a draft law with significant changes to TP rules
On 10 December 2019, Germany published a draft law implementing EU anti-tax avoidance directive. The Draft Law includes significant changes to the German transfer pricing rules. The following proposed changes have been taken place under the
See MoreLithuania: Parliament approves higher corporate income tax for banks
On 18 December 2019, Lithuanian lawmakers passed higher corporate tax for banks from January 2020. Higher corporate tax rate of 20% will apply to bank profit exceeding 2 million euros. Banks, like other legal entities in Lithuania, are now taxed at
See MoreDTA between Estonia and Hong Kong enters into force
On 18 December 2019, the Double Taxation Agreement (DTA) between Estonia and Hong Kong was entered into force and applies from 1 January 2020 for Estonia and from 1 April 2020 for Hong Kong. The DTA contains Dividends rate 0% if the beneficial
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