Czech Republic published law including CFC rules
On 27 March 2019, the Czech Republic released the Law of 12 March 2019, which includes CFC rules among other changes. A foreign company or permanent establishment will be considered controlled foreign company (CFC) for tax purpose if the Czech
See MoreZambia publishes Budget for 2019
On 1 January 2019, The Zambian government published budget for 2019 to the National Assembly. Key modifications of tax rules are summarized as follows: Limit the deductibility of interest on debts owed by a taxpayer to 30 % of the
See MoreAustralia: New guidance related to inbound distribution arrangements
On 13 March 2019, the Australian Taxation Office (ATO) released a PCG 2019/1 for all multinational enterprises (MNEs) with distribution operations in Australia. This Guideline outlines compliance approach to the transfer pricing
See MoreBolivia updates list of tax haven jurisdiction
On 15 February 2019, Bolivia's National Tax Service issued Resolution No. 101900000002 to update the list of jurisdictions considered to have low or no taxation, which also contains jurisdictions recognized as non-cooperative, applies from the date
See MoreSouth Africa introduces Budget 2019 in parliament
On 20 February 2019, Tito Mboweni (South Africa’s Minister of Finance) presented the Budget 2019 in the parliament. The budget proposal would not increase taxes in any category but proposed to increase tax collection by not adjusting for inflation
See MorePeru: Tax authority clarifies the scope of CFC rules
On 7 February 2019, the Peruvian Tax Authority published a report (097-2018-SUNAT / 7T00000) clarifying the passive net income attribution of CFC rules to its Peruvian shareholders. The Ministry of Finance simplifies the following issues in the
See MorePortugal: Parliament proposes to implements The Anti-Tax Avoidance Directive
Recently, the Portuguese Government has submitted to Parliament the Bill No.177/XIII introducing changes to the Income Tax Act to implement certain ATAD-1 rules. The bill proposed rules for the limitation of interest deductions and rules for
See MoreBelgium: Parliament approves new restriction on interest deduction
On 31 January 2019, the parliament of Belgium approved legislation implementing the 30% of Earnings before interest, tax, depreciation and amortization (EBITDA) restriction on interest deduction to 1 January 2019. The restriction is according to the
See MoreArgentina releases decree regarding tax reform measures for corporations
On 27 December 2018, Argentina published a Regulatory Decree 1170/2018 in the Official Journal, which entered into force on 28 December 2018. The decree prescribes policy changes to Law 27,430 of 2017, which introduced tax reform measures for 2018.
See MoreFrance: Parliament legislates the Finance Act for 2019
The French Finance Act passed its constitutional review for 2019 on 28 December 2018. This follows the approval of the law by Parliament on 20 December 2018. The main measures of the law are summarized as follows: Corporate Income tax rate:
See MoreColombia legislates the tax reform Bill for 2019
Colombia enacted tax reform (Law 1943-Tax Reform) on 28 December 2018. The Tax Reform makes numerous changes to the Colombian tax rules that generally apply from 1 January 2019. The tax reform includes following changes: Corporate tax: The Tax
See MoreLatvia: Parliament passes new CFC rules
On 13 December 2018, Latvian parliament Saeima passed a law of amending the corporate income tax act which provides for the implementation of new controlled foreign company (CFC) rules in line with the EU Anti-Tax Avoidance Directive (ATAD). The
See MoreUruguay: Tax authority revises list of low or no taxation countries and jurisdictions
On 17 December 2018, the tax authority of Uruguay published Resolution No. 10,730 revising the list of countries and jurisdictions with no or low taxation. The declared list of countries and jurisdictions are listed below: Andorra Falkland
See MoreDenmark: Ministry of Taxation publishes bill to implement EU ATAD with CFC amendments
Recently, the Danish Ministry of Taxation has published a legislation with CFC amendments for the implementation of the measure of the EU Anti-Tax Avoidance Directive (ATAD1) and the Directive as amended (ATAD2). Some of the main changes include:
See MoreDenmark: Ministry of Taxation publishes bill to implement EU ATAD
On 28 December 2018, the Danish Ministry of Taxation has published a new legislation (Law No 1726) for the implementation of the measure of the EU Anti-Tax Avoidance Directive (ATAD1) and the Directive as amended (ATAD2). The measures
See MoreItaly releases ATAD decree in line with EU Anti-Tax Avoidance Directive
On 28 December 2018, the Italian Government published, in the Official Gazette, the Legislative Decree (Decree) transposing the European Union (EU) Anti-Tax Avoidance Directive (ATAD) in the Italian legislation. The Government had previously
See MoreEstonia implements EU ATAD measures
On 28 December 2018, Estonia published the Income Tax Amendment Act in the Official Gazette, apply from 1 January 2019. The key measures of the Act provide the implementation of the EU Anti-Tax Avoidance Directive (ATAD) as urged by the European
See MoreRomania updates CFC and restriction on interest deduction rules
Romania has published Law no. 30 of 10 January 2019, which amendments restriction on interest deduction rules. The amendments increase safe harbor threshold from the RON equivalent of EUR 200,000 to the RON equivalent of EUR 1 million. It also
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