India: The new Finance Act modifies the Transfer pricing law
On 5 July 2019, the Minister of Finance presented the Finance (No.2) Act for the financial year 2019-20. The act changes the following transfer pricing rules: Documentations requirements: Under the new amendments, constituent entity of an
See MoreIreland introduces new Guidance on CFC rules
On 22 July 2019, Ireland has published a new Tax and Duty Manual, Part 35b-01-01 in respect of the Controlled Foreign Company (CFC) rules, that were introduced by Finance Act 2018 and take effect from 1 January 2019. The manual provides an
See MoreSingapore changes to FATCA reporting requirements with effect from 1 April 2020
On 10 July 2019, the Inland Revenue Authority of Singapore (IRAS) issued an announcement that, with effect from 1 April 2020, the IRAS will no longer accept FATCA (Foreign Account Tax Compliance Act) notifications submitted via the International
See MoreDenmark publishes a notice regarding transfer pricing documentation
On 12 July 2019, the Danish Tax Authority has published a notice (SKM2019.374.SKTST) which establishes a new practice for the importance of whether a transfer pricing documentation in its entirety is available at the time of tax return. The
See MoreArgentina: AFIP updates resolution on advance payment of tax
On 12 July 2019, the Federal Administration of Public Revenues (AFIP) of Argentina has published General Resolution No. 4522/2019 amending several provisions of General Resolution 4034 which was issued in 2017. The resolution modifies the
See MoreIndonesia publishes a regulation with tax incentives for investments in certain sectors
On 26 June 2019, the Indonesian government issued a Government Regulation (PP) No. 45 of 2019, which amended Regulation No. 94 of 2010 (GR-94) on the calculation of taxable income and the repayment of income taxes in the current year to stimulate
See MoreUK: Summary of responses to consultation on the restriction on offset of capital losses
On 11 July 2019 the UK government published a summary of responses to the consultation on the restriction of carried forward capital losses, which was held between 29 October 2018 and 25 January 2019. Interested parties submitting responses
See MoreUK: Summary of responses to consultation on digital services tax
On 11 July 2019 the UK government published a document summarising the responses to the consultation on the design of the digital services tax (DST). The DST is to be implemented from April 2020. Certain digital business models derive value
See MoreIMF report comments on Germany’s tax policy
On 10 July 2019, the IMF issued a report following the conclusion of the Article IV consultation with Germany. Germany’s real GDP growth has averaged over 2% for some years but slowed to 1.5% in 2018 owing to reduced global demand and
See MoreColombia publishes new thin capitalization rule
On 26 June 2019, the Government of Colombia published a Decree 1146 of 2019, concerning the new thin capitalization rules which amended the previous law 1943 of 2018. The new Decree 1146 of 2019 includes the following measures: The thin
See MoreWorld Bank approves grant to improve domestic revenue mobilization in Liberia
On 16 July 2019 the World Bank approved a grant to its International Development Association (IDA) to improve domestic revenue mobilization systems and strengthen financial control and accountability in public finances. The IDA provides grants and
See MoreOECD and Brazil: Report on project to align transfer pricing rules with OECD standards
On 7 July 2019 the OECD and Brazil’s tax administration (RFB) published a report on the results of the work programme launched in February 2018 to analyse Brazil's transfer pricing framework and the similarities and divergences between the
See MoreIndonesia: MoF changes CFC deemed dividend rules
On 26 June 2019, the Ministry of Finance published a new regulation (No.93/PMK.03/2019(PMK-93) on the controlled foreign corporation (CFC) rules for fiscal year(FY) 2019 which amended the regulation No.107/ PMK.03/2017(PMK-107), concerning the
See MoreLatvia publishes regulations for low value-adding intra-group services
On 9 July 2019, Latvia published Cabinet Regulations No. 324 of 9 July 2019 in the Official Gazette addressing simplified transfer pricing provisions for intra-group low value-added services. The Regulation provides that the general
See MoreAlgeria: DGI issues a guideline on electronic tax declaration
The Algerian tax agency Direction Generale des Impots (DGI) has recently published a guideline on electronic tax declaration and payment procedures. The guideline provides the following information: requirements to access the electronic
See MoreDenmark implements EU dispute resolution directive
The Act implementing Council Directive (EU) 2017/1852 of 10 October 2017 in Denmark entered into force on 30 June 2019. The Directive contains provisions on the effective resolution of disputes concerning the interpretation and application of
See MoreGreece: Tax authority clarifies the limitation period for the late filing of tax return
On 1 July 2019, the tax authority published the Circular E.2123 explaining the application of the limitation period in the event of late filing of a tax return. The new Circular amends Circular 1165/2018 in relation to the limitation period of 15
See MoreFrance issues new guidelines for GAAR
On 3 July 2019, the tax authorities published a guidelines regarding the new general anti-abuse rule (GAAR). The new GAAR, which applies from 1 January 2019, targets provisions that focus on tax-driven abuses of law. According to the guidance,
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