World Tax Brief: June 2019
Puerto Rico Incentives-Industry/manufacturing: 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
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 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 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 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 MoreTax Treaty News: April 2019
Qatar and Ukraine On 28 March 2019, Mr. Petro Poroshenko, the president of Ukraine signed a law ratifying the Double Taxation Agreement (DTA) with Qatar. Australia and Israel On 27 March 2019, the Double Taxation Agreement
See MoreWorld Tax Brief: April 2019
Greece Main corporate tax rates: On 21 March 2019, the Public Revenue Authority issued two circulars (E.2046/2019 and E.2047/2019) for reducing corporate tax rates and dividend tax rates. Accordingly the standard corporate tax rate in
See MoreTransfer Pricing Brief: April 2019
FinlandRestriction on interest deduction: On 7 March 2019, the Finnish tax administration published new guidelines on the rules on interest deduction restrictions, which were amended to comply with EU Anti-Tax Avoidance Directive (ATAD), and
See MoreTax Treaty News: March 2019
Korea (Rep.) and UAE On 27 February 2019, the revised Double Taxation Agreement (DTA) between Korea (Rep) and the United Arab Emirates (UAE) signed in Seoul. France and Luxembourg On 25 February 2019, France ratified the Double Taxation
See MoreTransfer Pricing Brief: March 2019
Hong Kong CbC reporting requirement-General rule: On 1 February 2019, Hong Kong Inland Revenue Department (IRD) announced that effective from 1 April 2019, the department will not accept voluntary filing of a CbC return for an accounting period
See MoreWorld Tax Brief: March 2019
Hong Kong Incentives for industry/manufacturing: On 27 February 2019, the Secretary of State presented the 2019/2020 Budget to the Legislative Council. The budget cuts profit tax for 2018/19 by 75%, subject to a ceiling of HKD 20,000, giving
See MoreWorld Tax Brief: February 2019
Colombia Main corporate tax rate: On 28 December 2018, Colombia enacted the Tax reform bill for 2019. The Tax Reform reduces the corporate income tax (CIT) rate from 33% in 2018 to 32% for 2020, 31% for 2021 and 30% for 2022 and onwards. The 4%
See MoreTransfer Pricing Brief: February 2019
Dominican Republic Documentation-Thresholds: On 17 January 2018, Directorate General of Internal Revenue (DGII) published the Transfer pricing (TP) reporting threshold for 2019. The DGII has issued Notice 8-19, which prescribes related party
See MoreTransfer Pricing Brief: January 2019
Costa Rica Interest limitation rule: On 4 December 2018, Costa Rica passed a tax reform bill which includes several tax reform measures. Under the law, an interest limitation rule applies which interest expenses that exceed 20% of the
See MoreTransfer Pricing Brief: December 2018
Finland Control: On 1 November 2018, the Ministry of Finance submitted a bill to Parliament proposing changes to the CFC rules. Under the proposed rules, the control threshold setting the CFC status would be reduced from 50% to 25%, and the
See MoreTransfer Pricing Brief: November 2018
Nigeria Documentation-Deadline: On 3 October 2018, Federal Inland Revenue Service published a notice granting taxpayers that they have until 31 December 2018 to satisfy all pending obligations pertaining to filing of TP declaration, making
See MoreTax Treaty News: October 2018
Austria and Japan On 27 October 2018, the Double Taxation Agreement (DTA) between Austria and Japan will enter into force. The DTA applies for assistance in the collection of taxes from 27 October 2018 and for other tax matters from 1 January
See MoreTransfer Pricing Brief: October 2018
Israel Priority of Methods: According to Circular 11/2018 published on 5 September 2018, in case of sales activity that is performed without significant marketing intangibles, the most appropriate transfer pricing method according to the ITA is
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