Tax Treaty News: December 2019
Ecuador and JapanOn 28 December 2019, the Double Taxation Agreement (DTA) between Ecuador and Japan will enter into force and applies from 1 January 2020 for other taxes.Czech (Rep.) and Korea (Rep.)On 28 November 2019, the Czech Senate
See MoreKazakhstan: Government extends deadline for new VAT obligations on digital service
On 6 November 2019, the government announced the extension of the deadline for applying VAT obligations. The new deadline is due on January 1, 2021, instead of January 1, 2020. Recently, the State Revenue Committee has proposed the introduction of
See MoreArgentina: Executive Power publishes Executive Branch Decree 862/2019
On 9th December 2019, the Executive Power published Executive Branch Decree 862/2019 in the Official Gazette, which approves a new revised text of the regulatory decree of the Income Tax Act and incorporated provisions that were contained in
See MoreAlgeria: President seals Finance Act 2020
The president of Algeria, Abdelkader Bensalah, signed the Finance Act 2020 into Law, on 11 December 2019, during a Council of Ministers he chaired. The Law includes tax incentives like profit tax and VAT exemptions for start-ups corporations and
See MoreIndonesia: Tax dispute resolution peer review report
On 28 November 2019 the OECD published a stage 1 peer review report commenting on Indonesia’s compliance with the minimum standard on tax dispute resolution under Action 14 of the project on base erosion and profit shifting (BEPS). The
See MoreUS: IRS issues final regulations on the base erosion and anti-abuse tax
On 2 December 2019, the Internal Revenue Service (IRS) issued final regulations and proposed regulations on the base erosion and anti-abuse tax. The Tax Cuts and Jobs Act (TCJA) made major changes to the tax law including revamping the U.S.
See MoreMexico implements economic package 2020
On 9 December 2019, Mexico has published a decree to implement economic package 2020 which was approved by Mexican Congress on 30 October 2019. This Decree will enter into force on January 1, 2020. The economic package consists of the following
See MoreUS: IRS publishes interest rate on overpaid and underpaid for first quarter of 2020
On 6 December 2019, The Internal Revenue Service announced interest rates for overpayments and underpayments that will remain the same for the calendar quarter beginning January 1, 2020. Accordingly, 5% for overpayments (4% in the case of a
See MoreSlovenia publishes guidance on the latest amendments to the CITA
On 2 December 2019, the tax authority has published guidance regarding the latest amendments to the Corporate Income Tax Act (CITA). The guidance also provides for a detailed description about implementation of the hybrid mismatch rules of the EU
See MoreSaudi Arabia introduces E-Service for CbC reporting
Recently, the General Authority of Zakat and Tax (GAZT) of Saudi Arabia have introduced E-Service for country-by-country (CbC) reporting. As per the transfer pricing Bylaws, Saudi Arabian taxpayers that are members of an MNE Group with consolidated
See MoreSerbia: Parliament amends the corporate income tax law including CbCR obligations
On 6 December 2019, the Serbian Parliament passed the legislation that amends the corporate income tax law including requirements for country-by-country (CbC) reporting of controlled transactions within a corporate group. The Law is published in
See MoreNew Zealand: Inland Revenue issues updated information on R&D tax incentives
On 29 November 2019, Inland Revenue of New Zealand has issued updated research and development (R&D) information and draft guidance on the latest proposals. The R&D tax incentives are included in the Taxation (KiwiSaver, Student Loans, and
See MoreTaiwan: MOF announces safe harbor rules for CbC report
On 10 December 2019, the Ministry of Finance (MOF) issued tax ruling no. 10804651540 providing exemption from CbC reporting for Taiwan entities under a MNE Group headquartered outside Taiwan. The safe harbor exemption guidance was issued in late
See MoreSweden publishes draft law to implement DAC6 reporting requirement
On 6 December 2019, the Swedish Ministry of Finance has published draft law on implementation of Council Directive (EU) 2018/822 of 25 May 2018 (DAC6) on reportable cross-border tax planning arrangements (DAC6). This includes measures to require
See MorePeru: SUNAT issues report on interest deduction limitations
On 29 November 2019, the Peruvian Tax Administration (SUNAT) has published Report No. 171-2019-SUNAT/7T0000 on its website regarding exception for the taxpayers engaged in public infrastructure projects, public services and applied research and
See MoreGreece: Parliament adopts tax reform measures
On 6th December 2019, Greek Parliament approved tax reform bill (Law 4646/2019), which contains several measures regarding corporate income tax, personal income tax, withholding tax rates, the participation exemption for capital gains
See MoreNigeria: House of Representatives passes Finance Bill 2019
On 28 November 2019, the House of Representatives passed the Finance Bill 2019. It was passed its third reading by the National Assembly on 21 November 2019. Major proposed amendments are given below: A lower (i.e. 20%) corporate income tax rate
See MoreIreland: Revenue publishes eBrief No. 202/19 regarding capital loss treatment
On 5th December 2019, the Irish Revenue Commissioners published eBrief No. 202/19 regarding guidance on the treatment of allowable losses for Capital Gains Tax (CGT) purposes. Under the eBrief No. 202/19, Tax and Duty Manual Part 19-02-05 has been
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