India: Parliament passes Taxation Laws (Amendment) Bill, 2019
On 5 December 2019, the upper house of parliament passed the Taxation Laws (Amendment) Bill, 2019. The bill was passed by the Lok Sabha (Lower house) on 2 December 2019. The bill repeals The Taxation Laws (Amendment) Ordinance, 2019. The bill also
See MoreBulgaria legislates amendments to the TP documentation threshold
On 6 December 2019, the Bulgarian Government published the amendments to the Act on Tax and Social Security Procedures in the Official Gazette. According to the amendments, the obligation to prepare such documents from 1 January 2020 will not apply
See MoreHigh Court rules that the Danish loss-making company could not deduct royalties paid to its Swiss parent
On 28 October 2019, the Eastern High Court of Denmark published a case (Denmark vs Adecco; Case No SKM2019.537.OLR of 4 July 2019) decision and agreed with the tax authority that a Danish loss-making company could not deduct royalties paid to its
See MoreBulgaria: Parliament approves the Budget for 2020
On 5 December 2019, Bulgaria's parliament has approved the 2020 budget Act for 2020. The budget envisages increased spending for pensions, salaries for teachers, and public sector salaries, as well as more funds for healthcare. The 2020 budget
See MoreLithuania proposes amendments to the CITL
On 31 October 2019, the parliament proposed a Bill (No. XIIIP-4116) to amend the Corporate Income Tax Law (CITL). The proposal includes the following measures: The taxable profit of a Lithuanian entities and a Lithuanian permanent
See MoreDenmark publishes the Bill no. L 48 on international taxation
On 6 November 2019, the Danish Minister of Taxation published Bill no. L 48 on international taxation. The bill updated the existing PE (permanent establishment) rules, CFC rules and strengthen the Transfer pricing (TP) rules. PE rules: The
See MoreEcuador presents new tax reform Bill
On 21 November 2019, the Ecuadorian National Assembly presented a new draft of the Tax Reform Bill on "Tax Simplicity and Progressiveness" following the rejection of the previous draft law on economic growth reform submitted to Congress on 18
See MoreOman signs MLI to implement tax treaty related BEPS measures
On 26 November 2019, Oman signed the Multilateral Convention to Implement Tax Treaty Related Measures to Prevent Base Erosion and Profit Shifting (MLI). Oman also signed the Multilateral Convention on Mutual Administrative Assistance in Tax
See MoreBulgaria approves changes to the TP documentation threshold
On 21 November 2019, the Bulgarian parliament approved amendments to the thresholds for mandatory preparation of a local transfer pricing file. According to the amendments, the obligation to prepare such documents from 1 January 2020 will not
See MoreSweden: Tax Agency issues guidance on DAC6 reporting
On 25 October 2019, the Swedish Tax Agency issued a guidance on the implementation of an EU Council Directive on the mandatory automatic exchange of information in relation to reportable cross-border arrangements (DAC6). The guidance includes the
See MoreIndia: Finance Minister introduces Taxation Law (Amendment) Bill, 2019
On 25 November 2019, the Finance minister Nirmala Sitharaman introduced the Taxation Laws (Amendment) Bill, 2019 in the lower house of Parliament (Lok Sabha). The Amendment Bill will replace Taxation Laws (Amendment) Ordinance, 2019, which aims to
See MoreGermany reduces the solidarity surcharge from 2021
On 14 November 2019, the lower house of the parliament adopted the draft bill on the reduction of the solidarity surcharge. The aim of the draft bill is the reduction of the 5.5% solidarity surcharge on corporate income tax liabilities that was
See MoreDenmark considers draft Bill to implement DAC6 reporting requirement
On 6 November 2019, the Danish Minister of Taxation published Bill no. L 49 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 MoreBulgaria: Parliament considers draft Bill to implement DAC6
On 14 November 2019, the National Assembly (NA) accepted for consideration a draft bill to transpose an EU directive on the mandatory automatic exchange of information in relation to reportable cross-border arrangements (DAC6). The NA is currently
See MoreBulgaria proposes changes to the Corporation Tax Act
On 12 November 2019, a proposal to changes the Corporation Tax Act was submitted to Parliament. The law proposed the following measures: propose to amendments the thin capitalization rules in order to increase the level of expenditure that is
See MorePortugal: Administrative Court issued a decision on Transfer Pricing case
On 10 October 2019, in the case of : n.º 511/2018-T, the Administrative Court issued a decision on the sale of raw materials and goods by a company to related parties. In particular, concerning an undervalued controlled transaction tested using
See MoreRussia: MOF clarification on CFC profits
On 5 November 2019, the Russian Ministry of Finance (MOF) issued the letter No. 03-03-06 / 1/85022 concerning the profits of controlled foreign companies (CFC) in cases where a controlling person has an indirect participation in a CFC through legal
See MoreBulgaria submits proposal to amends the TP documentation threshold
On 12 November 2019, some of policy makers submitted to Parliament a proposal to amend the rules on thresholds for the Transfer Pricing (TP) documentation rules. It is proposed that the obligation to prepare such documents will not apply to persons
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