Indonesia: MoF changes CFC deemed dividend rules
On 26 June 2019, the Ministry of Finance published a new regulation (No.93/PMK.03/2019(PMK-93) on the controlled foreign corporation (CFC) rules for fiscal year(FY) 2019 which amended the regulation No.107/ PMK.03/2017(PMK-107), concerning the
See MoreFrance issues new guidelines for GAAR
On 3 July 2019, the tax authorities published a guidelines regarding the new general anti-abuse rule (GAAR). The new GAAR, which applies from 1 January 2019, targets provisions that focus on tax-driven abuses of law. According to the guidance,
See MoreRussia: MOF clarifies the ‘related party’ for transfer pricing purposes
Recently, the Russian Ministry of Finance has adopted a guidance letter (No. 03-12-12 / 1/39688 of 05.31.2019) clarifying the recognition of persons as related for transfer pricing purposes. The Guidance Letter No. 03-12-12/1/39688 says that
See MoreCzech Republic: Ministry of Finance releases latest guidance on transfer pricing
On 31 May 2019, Czech Ministry of Finance published Guidance GFR D-34 on the application of international standards to the taxation of related party transactions. The guidance replaces existing Guidance D-332. Together with this new guidance,
See MoreSingapore: IRS Publishes TP guidelines for commodity marketing and trading activities
On 24 May 2019, the Inland Revenue Service of Singapore (IRS) has published a new transfer pricing (TP) E-Tax guide aimed at helping taxpayers compute the economic value of commodity marketing and trading activities conducted by related parties.
See MoreNew Zealand: Inland Revenue publishes revised transfer pricing regime
On 29 April 2019, Inland Revenue published the final versions of the special reports on the new rules for base erosion and profit shifting (BEPS). The rules were enacted in the Taxation (Neutralising Base Erosion and Profit Shifting) Act 2018 on 27
See MoreGreece transposes the rules of the EU Anti-Tax Avoidance Directive
On 24 April 2019, Greece published Law 4607/2019 in the Official Journal containing measures to implement certain aspects of the EU's Tax Avoidance Directive (ATAD). This includes the replacement of existing rules to bring them in line with ATAD.
See MorePakistan: FBR publishes ordinance on the tax amnesty program for a voluntary declaration
On 16 May 2019, the Pakistani Federal Board of Revenue (FBR) posted online an ordinance on the tax amnesty program for a voluntary declaration of undisclosed assets, sales, and expenditures acquired through June 30, 2018. The Ordinance will
See MorePeru: 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 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 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 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 MoreCyprus: House of Representatives approves law for ATAD Interest Limitation, CFC, and GAAR Rules
On 5 April 2019, the Cyprus House of Representatives passed a law that addresses certain provisions of the EU anti-tax avoidance directive (ATAD 1) particularly the interest limitation rule, a general anti-avoidance rule (GAAR) and controlled
See MoreUganda: Minister of Finance presents tax reform bills to Parliament
On 28 March 2019, Mr. Matia Kasaija, the Minister of Finance, Planning and Economic Development (Minister of Finance) of Uganda presents a number of tax reforms amendment bills to the Ugandan parliament and are currently under consideration. The
See MoreZambia: Tax Appeals Tribunals decision on arm’s length arrangements between related parties
Recently, the Tax Appeals Tribunal (TAT) issued a decision for the Zambia Revenue Authority (“ZRA”) in the case of: Nestlé Zambia Trading Limited v. Zambia Revenue Authority TAT 03, regarding transfer prices used with respect to its
See MorePeru: SUNAT simplifies the scope of the CFC rules
On 19 March 2019, the Peru tax authority (SUNAT) issued a guidance (No. 011-2019-SUNAT/7T0000) regarding the determination of expenses and loss offsetting under the controlled foreign company (CFC) rules. The guidance clarified that:
See MoreJapan: Parliament enacts tax reform plans for 2019
On 27 March 2019, Japan's parliament approved the legislation for the government's tax reform proposals for 2019. Some of the main measures are following: Tax incentive: As from 1 April 2019, the tax credit rates will be revised to enhance
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