Singapore: IRS Publishes TP guidelines for commodity marketing and trading activities
On 24 May 2019, the Inland Revenue Service of Singapore (IRS) has published a new transfer pricing (TP) E-Tax guide aimed at helping taxpayers compute the economic value of commodity marketing and trading activities conducted by related parties.
See MoreTransfer Pricing Brief: June 2019
HungaryDocumentation-Timing: On 8 May 2019, the Hungarian National Tax and Customs Administration issued a notice to remind taxpayers that they must prepare their transfer pricing documentation by 31 May 2019 if they are required to keep
See MoreDTA between Ukraine and Qatar enters into force
On 9 April 2019, the Double Taxation Agreement (DTA) between Ukraine and Qatar was entered into force and applies from 1 January 2020. The agreement contains Dividends rate 5% for at least 10% capital holding; otherwise 10%, Interest rate
See MoreGreece amends tax incentives to extend the shared services centers
On 14 May 2019, Greece published document No. Ε.2076, sets forth the provisions of article 38 of Law 4605/2019 (Official Gazette Issue A’ 52/1 April 2019) amending the provisions of Law 89/1967, to broaden the relevant framework and incentivize
See MoreOECD: Work plan on taxation of digital economy
The OECD reported on 31 May 2019 that a program of work has been agreed for work to reach agreement on the tax challenges arising from the digitalisation of the economy. A document has been issued outlining a plan for continuing discussion around
See MorePuerto Rico proposes tax incentives for qualifying Opportunity Zones
On 14 May 2019, Governor of Puerto Rico signed the Senate Bill 1147 (the Opportunity Zones Development Act), offering tax incentives for investments in qualifying Opportunity Zones. The act permits the investors following benefits: The new act
See MoreNew Zealand: Inland Revenue publishes revised transfer pricing regime
On 29 April 2019, Inland Revenue published the final versions of the special reports on the new rules for base erosion and profit shifting (BEPS). The rules were enacted in the Taxation (Neutralising Base Erosion and Profit Shifting) Act 2018 on 27
See MorePhilippines: DOF submits tax reform bill to Congress
The Philippines Department of Finance (DOF) has announced on 25 April 2019 that the second package (Tax Reform for Attracting Better and High-Quality Opportunities or TRABAHO) of the Duterte administration’s Comprehensive Tax Reform Program
See MorePoland publishes law amending CbC reporting rules
On 15 April 2019, Poland published the Act of 4 April 2019 amending the Act on the exchange of tax information with other countries and certain other acts including Country-by-Country (CbC) reporting rules. Under this, if a group prepares its
See MoreBelgium Updates XML Tool and the XSD schema for Local File
The Belgian Federal Public Service (SPF) Finance has published an update version 2.1 of the XML tool and the XSD schema for the Transfer Pricing (TP) Local file (Form 275 LF), which must be used for Local files submitted via the MyMinfin platform
See MoreBelgium updates TP notification requirement
The annual Country-by-Country (CbC) notification requirement has been amended by the law of 2 May 2019 that was published in the Belgian Official Gazette on 15 May 2019. This new law amended Belgian Transfer Pricing (TP) reporting
See MoreIndonesia: MoF publishes new guidance on MAP
On 26 April 2019, the Minister of Finance (MoF) issued a new provision on the Mutual Agreement Procedure (MAP) with Regulation No. 49 / PMK.03 / 2019 (PMK-49). PMK-49 is effective from 26 April 2019 and repeals MoF Regulation No. 240 / PMK.03 /
See MoreGreece transposes the rules of the EU Anti-Tax Avoidance Directive
On 24 April 2019, Greece published Law 4607/2019 in the Official Journal containing measures to implement certain aspects of the EU's Tax Avoidance Directive (ATAD). This includes the replacement of existing rules to bring them in line with ATAD.
See MorePakistan: FBR publishes ordinance on the tax amnesty program for a voluntary declaration
On 16 May 2019, the Pakistani Federal Board of Revenue (FBR) posted online an ordinance on the tax amnesty program for a voluntary declaration of undisclosed assets, sales, and expenditures acquired through June 30, 2018. The Ordinance will
See MoreBulgaria: Council of Ministers approves the proposals of new mandatory documentation rule for transfer pricing
On 15 May 2019, the Council of Ministers approved the proposals of the Ministry of Finance to amend the Rules of Procedure on taxes and social security. The amendments concern the introduction of compulsory transfer pricing documentation and the
See MoreIndia: CBDT signs 18 new APAs
On 3 April 2019, the Central Board of Direct Taxes (CBDT) has announced the signing of 18 advance pricing agreements (APAs) during March 2019, including three bilateral APAs. With the signing of these APAs, the total number of APAs entered into
See MoreBrazil publishes general rules regarding shareholder interest on net equity
On 6 May 2019, Brazil has published general rules 7018 of 21 March 2019 in the official gazette clarifying calculation and deduction of interest on net equity. The calculation will take into account for the following equity
See MoreArgentina implements new rules for withholding tax on dividends
On 9 May 2019, Argentina has published General Resolution 4478/2019 in the official gazette amending the withholding tax rates on dividends. The new rules explain the following measures: Retention Procedures Generally, the withholding tax is
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