UK: Consultation on tax dispute resolution
On 2 July 2019 the UK government published for consultation draft Regulations to implement EU Council Directive 2017/1852 on tax dispute resolution mechanisms. Under the draft Regulations a stronger system of dispute resolution would be introduced
See MoreQatar: GTA issues additional CbC reporting obligations
On 16 June 2019, Qatar's General Tax Authority (GTA) has issued a notice prescribing further updates and clarifications for the Country-by-Country (CbC) reporting obligations in Qatar. Key points of CbC reporting obligations are as follows:
See MoreMalta: Commissioner for revenue issues updated MAP guidelines
Earlier the month of June 2019, the Maltese Commissioner for Revenue issued guidance under the provisions of article 96(2) of the Income Tax Act, Chapter 123 of the Laws of Malta (the ‘ITA’) on the use of Mutual Agreement Procedure
See MoreFrance publishes interest rate for shareholder loan for FY ends between June and September 2019
Recently, France has published interest rates for entities whose financial year ended between 30 June 2019 and 29 September 2019 , which are used to determine the deductibility of interest payments to shareholders. The portion of interest payments
See MoreSlovenia proposes to change the PIT & CIT rates
On 18 June 2019, the Ministry of Finance proposed changes to personal income tax (PIT) and corporate income tax (CIT) rates, which are expected to be introduced in 2020. The proposed measures are: Individual tax: An increase in the
See MoreIndia deposits ratification instrument for MLI
On 25 June 2019, India has deposited its instrument of ratification for the Multilateral Convention to Implement Tax Treaty Related Measures to Prevent Base Erosion and Profit Shifting (MLI). According to Article 34, Paragraph 2 of the MLI, with
See MoreRussia: Parliament approves law on submission of CbC reports
On 7 June 2019, the Russian parliament passed Law No. 125-FZ in the Official Gazette. The Act amends Article 105.16.3 of the Tax Code on the submission of country-by-country (CbC) reports by multinationals (MNE). The amendments extend the list
See MoreAustralia provides additional 15 days for CbC statement lodgment
The Australian Taxation Office (ATO) has provided additional 15 days for the lodgment of CbC statements (Local File, Master File, CbC report) with 30 June 2019 due date because of technical issues. This additional time will apply automatically
See MoreChina updates expense deduction limit for insurance sector
China's Ministry of Finance (MoF) has published Announcement No. 72 of 2019 regarding pre-tax deduction policy for insurance enterprise handling fees and commission expenses. The announcement provides that insurance companies may deduct up to
See MoreCanada: Federal budget 2019 bill enacted
On 21 June 2019, Canada’s corporate income tax measures as included in three federal bills are deemed to be substantially enacted. The summary corporate tax measures are following: Increasing 15% tax credit for mineral
See MorePoland publishes explanatory note addressing transfer pricing comparability analyses
On 19 June 2019, Poland Ministry of Finance published an explanatory note addressing transfer pricing comparability analyses. Accordingly, database for comparables could be selected locally, regionally, or even globally by considering
See MorePortugal approves MLI
On 21 June 2019, the Portugal's parliament approved the resolution for the ratification of the Multilateral Convention to Implement Tax Treaty Related Measures to Prevent Base Erosion and Profit Shifting (MLI). After the ratification process,
See MoreSouth Africa: Tax benefits for investors through Section 12J VCC regime
In 2009 Government implemented a tax incentive for investors in privately owned entrepreneurial businesses in South Africa to assist small and medium sized enterprises (SMEs) with access to equity finance. Individuals, companies and trusts (any SA
See MoreIndonesia: MOF proposes draft amendments to the SEZ scheme and tax cuts
The Indonesian Ministry of Finance (MoF) published two announcements on June 17 and 20 June 2019. The ministry is reviewing draft amendments to the Special Economic Zones (SEZ) regime and tax cuts for specific sectors. SEZ regime: Under this
See MoreUruguay: New incentive for software development
Uruguay has published Decree No 96/2019 of 22 April 2019 amending exemption incentive for software development with effect from 1 January 2018 to comply with BEPS Action 5. The decree applies retroactively from 1 January 2018. The Decree
See MoreRussia proposes Transfer Pricing and MAP-related changes
The Russian Ministry of Finance has proposed some transfer pricing amendments (Draft legislation No. 720839-7) and submitted them to the State Duma for approval (preliminary examination of the draft law submitted to the State Duma). The draft law
See MoreSaudi Arabia: GAZT holds seminar to simplify the transfer pricing regulations
On 17 June 2019, the General Authority of Zakat and Tax (GAZT) of Saudi Arabia has organized a transfer pricing seminar in Riyadh to simplify the key areas of the transfer pricing (TP) regulations published on 15 February 2019 and to address
See MoreNetherlands: Consultation on tax group regime
The Finance Ministry of the Netherlands has announced the launch of a public consultation on the design of a new corporate tax group regime to replace the current fiscal unity regime. The consultation includes four possible
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