World Tax Brief: December 2019
DenmarkPE rules: On 6 November 2019, the Danish Minister of Taxation published a bill L.48 on international taxation. The bill proposed to change the domestic PE definition in order to align with the new definition in Article 5. CFC rules:
See MoreTransfer Pricing Brief: December 2019
DenmarkDocumentation-Deadlines: On 6 November 2019, the Danish Minister of Taxation published Bill no. L 48 on international taxation. Accordingly, transfer pricing documentation must be submitted to the tax authorities no later than 60 days
See MoreTax Treaty News: November 2019
Spain and USOn 27 November 2019, the amending protocol to the Double Taxation Agreement (DTA) between Spain and the United States (US) will enter into force and applies from the date of its entry into force.Czech Republic and
See MoreWorld Tax Brief: November 2019
Russia Interest on late payments: On 25 October 2019, the Russian Central Bank reduced the interest rate from 7% to 6.5% with effect from 28 October 2019.See the story in RegfollowerTax base: On 30 September 2019, the Russian
See MoreTransfer Pricing Brief: November 2019
SloveniaMain corporate income tax rate: Slovenia increased the corporate income tax rate from 19% to 20% with minimum tax rate 7% under the amendments of corporate income tax act. Special rules for hybrid instruments or entities: Slovenian
See MoreTax Treaty News: October 2019
Estonia and Hong KongOn 25 September 2019, the Double Taxation Agreement (DTA) between Estonia and Hong Kong was signed for the avoidance of double taxation and the prevention of fiscal evasion with respect to taxes on income, in
See MoreWorld Tax Brief: October 2019
Costa Rica Computation of taxable income: On 25 September 2019, the Costa Rican Ministry of Finance issued a Resolution No DGT-R-55-2019 on the list of non-cooperative jurisdictions for tax purposes. According to the list, all expenses
See MoreTransfer Pricing Brief: October 2019
GreeceCbC reporting requirement: On 17 September 2019, the Greek Public Revenue Authority (AADE) released a Circular 1341 / 09-09-2019 containing amendments regarding the submission process of CbC notifications. Under this new Circular,
See MoreWorld Tax Brief: September 2019
TaiwanBusiness income taxation: On 26 August 2019, the Taiwan National Tax Bureau for the Northern Area (NTBNA) published a notice for domestic companies. The Notice clarifies that domestic companies purchasing e-services from a foreign
See MoreTax Treaty News: September 2019
Kosovo and Malta On 20 September 2019, the Double Taxation Agreement (DTA) between Kosovo and Malta will enter into force and applies from 1 January 2020.Croatia and Japan On 5 September 2019, the Double Taxation Agreement (DTA)
See MoreTransfer Pricing Brief: September 2019
AustraliaFinancial services: On 28 August 2019, the Australian Taxation Office (ATO) published draft Practical Compliance Guideline PCG 2019/D3, which sets out the proposed compliance approach for the use of the arm’s-length debt test (ALDT)
See MoreTax Treaty News: August 2019
Indonesia and UAEOn 24 July 2019, Indonesia and the United Arab Emirates (UAE) signed an amending protocol to the Double Taxation Agreement (DTA) in Jakarta. Ukraine and UAEOn 24 July 2019, the Cabinet of Ukraine approved to sign an
See MoreWorld Tax Brief: August 2019
HungaryIncentive on small business: On 12 July 2019, the Hungarian Lawmakers approved the 2020 budget. The budget reduced the rate of small enterprise tax (KIVA) from 13% to 12% and cancel the simplified entrepreneurial tax (EVA). Payment
See MoreTransfer Pricing Brief: August 2019
MalaysiaRestriction on interest deduction: On 5 July 2019, the Inland Revenue Board of Malaysia has published new guidance on restrictions to the deductibility of interest expenses. Under the rules the maximum amount of deductible interest is
See MoreTransfer Pricing Brief: July 2019
PanamaCbC reporting requirement-General rule: On 27 May 2019, Panama introduced Country-by-Country (CbC) reporting requirements for MNE’s whose consolidated group revenue exceeds €750 million. Timing: The CbC report must be filed no
See MoreWorld Tax Brief: July 2019
SloveniaCorporate income tax rate: On 18 June 2019, the Ministry of Finance proposed changes to corporation tax rates. As a result, the CIT rate increased by one percentage point from 19% to 20% from 2020 onwards. In addition, a minimum
See MoreTax Treaty News: July 2019
Zambia and ChinaOn 27 June 2019, the Double Taxation Agreement (DTA) between Zambia and Italy was signed in Osaka.Cambodia and Hong Kong On 26 June 2019, the Double Taxation Agreement (DTA) between Cambodia and Hong Kong was signed
See MoreTax Treaty News: June 2019
Russia and Sweden On 1 July 2019, the amending protocol of Double Taxation Agreement (DTA) between Russia and Sweden will enter into force to update the Exchange of Information Article in accordance with the OECD standard for
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