Costa Rica publishes a resolution on the list of non-cooperative jurisdictions for tax purposes
On 25 September 2019, the Costa Rican Ministry of Finance published a resolution No. DGT-R-55-2019 on the list of non-cooperative jurisdictions for tax purposes. The list includes Bosnia and Herzegovina, Cuba, Eritrea, French Polynesia, Guadeloupe,
See MoreIndia: ITAT ruled that the Liaison Office of Hitachi constitutes a PE
On 17 September 2019, the Delhi Bench of the Income Tax Appellate Tribunal (ITAT) in the case of: Hitachi High Technologies Singapore Pte Ltd vs. DCIT , held that a Liaison Office (LO) of Hitachi Technologies Singapore Pte Limited constituted a
See MoreLuxembourg: EU General Court upholds EC Commission’s decision in Fiat case
On 24 September 2019, the EU General Court upheld the Commission’s decision that Fiat received unlawful State aid from Luxembourg, and at the same time cancelled the decision which had found the same with respect to Starbucks in the
See MoreGreece: AADE publishes Circular 1341 / 09-09-2019 on CbC notification process
On 17 September 2019, the Greek Public Revenue Authority (AADE) released a Circular 1341 / 09-09-2019 containing amendments to Decision POL. 1184 of 22 November 2017 regarding the submission process of CbC notifications. Under this new Circular,
See MoreBelgium announces compliance for pre-filing requests regarding TP
The Belgian ruling commission has announced that pre-filing requests or ruling requests concerning Transfer Pricing (TP) or the patent income deduction regarding the corporate income tax return that will be filed by the end of September 2020 must
See MoreEgypt: MOF issues draft budget for 2019-2020
On 21 September 2019, Egypt’s Ministry of Finance (MOF) has issued draft budget for 2019-2020 which is scheduled to be discussed during the next parliamentary session. The draft budget includes following tax incentives: The draft budget
See MoreGermany publishes new draft of DAC 6 implementation law
On 26 September 2019, federal government of German issued a draft proposal regarding the implementation of mandatory disclosure rules pursuant to the EU’s Council Directive 2018/822 of 25 May 2018 (commonly referred to as DAC 6) into Germany’s
See MoreHong Kong and Estonia sign new tax treaty
On 25 September 2019, the Secretary for Financial Services and the Treasury of Hong Kong and the Minister of Finance of Estonia signed a comprehensive avoidance of double taxation agreement (CDTA) in Tallinn, Estonia. The agreement sets out the
See MoreNigeria: FIRS issues Income Tax (CRS) Regulations, 2019
Recently, the Federal Inland Revenue Service (FIRS) issued the Income Tax (Common Reporting Standard (CRS)) Regulations, 2019. The effective date of the regulations is 1 July 2019. This follows Nigeria's signing of the Multilateral Convention on
See MoreMalaysia withdraws withholding tax exemptions available to MSC Malaysia status companies
Malaysia Digital Economy Corporation Sdn Bhd (MDEC) has recently announced on its website that the withholding tax (WHT) exemption on certain types of income received by a non-resident company from an approved Multimedia Super Corridor (MSC)
See MoreUkraine submits draft law on amendments to the Tax Code to Parliament
On 30 August 2019, the Ukraine has submitted draft law no. 1210 to the Parliament amending the Tax Code on improving tax administration, removing technical and logical mismatches in the tax legislation. The three main areas of the draft law
See MorePeru: SUNAT publishes report on GAAR
On 17 September 2019, the Peruvian Tax Administration (SUNAT) published Report No. 116-2019-SUNAT / 7T000 of 27 August 2019 on its website, through which SUNAT clarifies the application of General Anti-Avoidance Rule (GAAR). On 19 July 2012,
See MoreUkraine: MOF amends taxpayer’s audit compliance with the arm’s length principle
On 6 September 2019, the Ukrainian Ministry of Finance (MOF) has published Order No. 307 of 16 July 2019 in the official gazette amending Order No. 399 of 30 March 2017. The amendment clarifies the procedures to audit compliance with the arm’s
See MorePortugal legislates EU Directive on Dispute Resolution
On 19 September 2019, the Portuguese Official Gazette published a Law no. 120/2019, the new law establishes dispute settlement mechanisms involving the competent authorities of Portugal and other Member States of the European Union as a result of
See MoreThailand: BOI approves Thailand Plus incentive package
On 20 September 2019, Thailand Board of Investment (BOI) approved a set of new incentive measures aimed at attracting foreign business to relocate and expedite large-scale investment as well as strengthening workforce development. These new
See MoreFinland: MFN clause applies in tax treaty with Lithuania
On 2 September 2019, Finnish tax authority published a statement no.67/2019 regarding the application of the most-favored nation (MFN) clause in article 12(7) (Royalties) of Finland’s tax treaty with Lithuania. Under the MFN clause, effective
See MorePhilippines: BIR issues guidelines for transfer pricing audits
The Bureau of Internal Revenue (BIR) has issued Transfer Pricing Audit Guidelines under Revenue Audit Memorandum Order (RAMO) No. 1-2019 on 20 August 2019, which provides standardized audit procedures and techniques in auditing taxpayers with
See MoreIndia cuts corporate tax rate for domestic companies
On 20 September 2019, the Government of India introduced the Taxation Laws (Amendment) Ordinance, 2019. According to the Ordinance, the government makes certain changes to the Income Tax Act of 1961 and the Finance Act (No 2) of 2019. The main
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