Peru: SUNAT issues a new transfer pricing guideline on related-party share transfers
On 16 May 2019, Peruvian tax administration published a guidance “Informe No. 057-2019-SUNAT/7T0000” outlining the tax treatment of transfers of undervalued Peruvian entity shares involving foreign related parties. Under this any transfer
See MorePeru publishes conditions and procedures to implement GAAR
On 6 May 2019, the Peruvian Minister of Economic issued a Supreme Decree 145-2019-EF, which contains the provisions for the Peruvian General Tax Avoidance Scheme (GAAR) for tax purposes, which allow the Peruvian tax administration to prevent tax
See MoreAustria: MoF proposes draft legislation regarding tax reform for 2019-2020
On 8 May 2019, the Austrian Ministry of Finance published a draft bill regarding tax reform for 2019-2020. The main measures of the draft bill are following: -A reduction in the corporate tax rate from 25% to 23% in 2022 and to 21% in
See MoreTax Treaty News: May 2019
Romania and Turkmenistan On 24 April 2019, the government of Romania approved to sign an amending protocol to update the Double Taxation Agreement (DTA) with Turkmenistan.South Sudan and UAEOn 23 April 2019, the Double Taxation
See MoreHungary: NTC publishes a notice to remind taxpayers for deadline of TPD
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 transfer pricing records and closed
See MoreTaiwan issues a notice on businesses optimized tax regulations
On 15 May 2019, The National Taxation Bureau of the Northern Area (NTBNA) of Taiwan published a notice upon businesses of optimized tax regulations in order to simplify the tax system and comply with international trends (the Income Tax Act was
See MorePortugal legislates the EU ATAD into domestic law
On 3 May 2019, Portugal published Law n. 32/2019 in the Official Journal which introduced amendments to the Portuguese Tax Law in line with the European Union (EU) Anti-Tax Avoidance Directive (ATAD) provisions. The law amends the following
See MoreBelgium extends deadline for filing CIT return
The tax authority of Belgium has declared corporate income tax (CIT) return filing deadlines for the 2019 tax year, with a concession for those with a deadline prior to September 26, 2019. Generally, tax returns are due by the last day of the
See MoreColombia: DIAN simplifies the scope of new thin capitalization rule
On 5 April 2019, the tax Authority (DIAN) of Colombia published an opinion No. 8159, concerning the scope of the thin capitalization rule, ratification with the Financing Law (Law 1943 of 2018). Accordingly, as from taxable year 2019, the thin
See MoreBelgium: New law with withholding tax exemption on dividends
On 6 May 2019, Belgium published in the Official Gazette the Law of 28 April 2019 on various tax provisions along with the amendment of Article 264 of the Income Tax Code, which provides for an exemption from withholding tax on dividends
See MoreWorld Tax Brief: May 2019
MexicoIncentives-Industry/manufacturing: On 29 April 2019, the Mexican Tax Administration has published the Miscellaneous Tax Code of 2019. Accordingly, the regulations grants special tax incentive decree for interest on corporate debt
See MoreItaly releases a decree of urgent economic growth measures
On 30 April 2019, Italy publishes a decree regarding “urgent economic growth measures” (Decreto Crescita) which entered into force on 1 May 2019. Under the decree following tax incentives are introduced; As an extra or bonus depreciation
See MoreIreland commences Public Consultation on R&D Tax Credit
Ireland's Department of Finance has launched a public consultation on a review of the 25% research and development (R&D) tax credit, which was introduced in the Finance Act 2004 to encourage companies to undertake high-value-add
See MoreKenya: KRA releases a notification on taxation of e-commerce
On 3 May 2019, the Kenya Revenue Authority (KRA) published a public notification on the taxation of e-commerce regarding some taxpayers carry on online business and they do not file returns or pay taxes on the transactions. The tax authority
See MoreMexico publishes Annexes to Miscellaneous Tax Resolution 2019
On 29 April 2019, Annexes of the Miscellaneous Tax Resolution for fiscal year 2019 (Resolución Miscelánea Fiscal para 2019, RMF 2019) were published in the Official Gazette published. The location of the administrative units of the Tax
See MoreTransfer Pricing Brief: May 2019
JapanAudit Rules-Statute of limitation: On 27 March 2019, the Parliament of Japan adopted the legislation for the government's tax reform proposals for 2019. Accordingly, the statute of limitations for transfer pricing purposes is extended
See MorePeru: SUNAT issues a rule on Interest paid on loans from related parties
On 23 April 2019, the Tax Administration (SUNAT) of Peru issued Administrative rule 033-2019-SUNAT/7T0000 regarding the application of the Peruvian thin capitalization rules which specify a restriction of the deduction of interest on loans where a
See MoreIndonesia: MOF publishes regulations on permanent establishment’s rules
On 1 April 2019, the Minister of Finance (MoF) of Indonesia Published Regulation No. 35 / PMK.03 / 2019, on what constitutes a permanent establishment (PE).The main measures contain that are: According to the Regulation (PMK-35), the following
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