Croatia: MoF publishes a draft bill covering various sectors
The Finance Minister, Zdravko Marić, on August 16, 2018, published draft bill on amendments to the Law on administrative cooperation in tax matters. This Act shall enter into force on the eighth day after its publication in the Official Gazette
See MoreRussia modifies transfer pricing rules
On 3 August 2018, the President of the Russian Federation signed Law No. 302-FZ About changes to Part One and Two of the Tax Code of the Russian Federation" Once the new law enters into force, only transactions between Russian companies that apply
See MoreFinland: Ministry of Finance officially submits its budget proposal for the year 2019
On 9 August 2018, the Ministry of Finance officially submitted its budget proposal for next year 2019. The budget introduced changes to the CFC definition and applicable exemptions, including reducing the control threshold for a company that
See MoreUK: Statistics on transfer pricing and diverted profits tax
On 1 August 2018 HMRC released a document showing the latest statistics relating to transfer pricing and the diverted profits tax (DPT). The transfer pricing rules and the DPT are seen by HMRC as an important part of the range of measures in place
See MoreAustralia: Improving the integrity of the thin capitalization rules
The Australian Government announced that it will implement two changes to improve the integrity of Australia’s thin capitalization rules in the 2018-19 Budget. The changes are: requiring entities to align the value of their assets for thin
See MorePoland releases draft law amending transfer pricing rules
On 16th July 2018, Poland has released a bill to amend the country's transfer pricing rules in line with the results of the BEPS project and the OECD transfer pricing guidelines 2017 in order to improve the taxation of large multinational companies.
See MoreAustria: Parliament adopts the annual Tax Act 2018
On 11 July 2018, the Federal Council of Austria adopted the text of the Annual Tax Act 2018 as approved by the National Council (lower house) on 4 July. The legislation includes simplifications of tax laws, the abolishment of various fees and
See MoreUkraine: President submits draft law on withdrawn capital tax to Parliament
On 4 July 2018, the President of Ukraine presented to Parliament the draft law "On amendments to the Tax Code of Ukraine concerning the tax on the withdrawn capital". The draft law amends the tax law to replace the current corporate income tax
See MoreMexico: The tax authority issues new rules regarding transfer pricing adjustments
On July 11, 2018 the Mexican Tax Authority (SAT) has published amendments to the rules for transfer pricing adjustments now included in rules 3.9.1.1-3.9.1.5 of Resolución Miscelánea Fiscal (RMF). These rules include the definition of transfer
See MoreRussia: Parliament considering the Bill amending CFC and other rules
Recently, the Russian lower house of parliament considering the Bill No. 442400-7, which includes various measures. The Bill includes following measures: 1. Adjust the CFC rules so that a person will not be recognized as a controlling person of a
See MoreBrazil clarifies CFC rule regarding exemption for oil and natural gas industry
Private Ruling 4,020/2018 concerning the exemption under CFC rules for profits acquire by the oil and gas industry was published in the Official Gazette on 19th June 2018. The Decision clarifies that the tax exemption of the profits realized is
See MoreAustralia: ATO publishes draft guidance on transfer pricing issues
The Australian Taxation Office (ATO) has issued Draft Schedule 2 to Practical Compliance Guideline (PCG) 2017/1 ATO compliance approach to transfer pricing issues related to centralized operating models involving procurement, marketing, sales and
See MoreLuxembourg: Government submits EU Anti-Tax Avoidance Directive (ATAD) to Parliament
On 20 June 2018, the draft law (Draft Law) implementing the European Union (EU) Anti-Tax Avoidance Directive (ATAD) was introduced in the Luxembourg Parliament. Accordingly, as from 2019, a new provision will be introduced that limits interest
See MoreLuxembourg: Cabinet approves draft law for implementation of EU anti-tax avoidance directive
On 15 June 2018, the Luxembourg Cabinet approved a draft bill providing for measures to implement the EU Anti-Tax Avoidance Directive (ATAD). The draft bill includes the new provisions on the limitation of interest deduction, which limit the
See MorePakistan enacts Finance Bill 2018
The Finance Bill, 2018 was passed by the government on 22 May 2018, with some amendments. The Bill provides for the implementation of the measures proposed as part of the 2018-2019 Budget. The main measures are summarized as follows: Corporate
See MoreAustralia updates international dealings schedule for 2018 tax year
The Australian Taxation Office (ATO) has released the 2018 International dealings schedule (IDS) and their instructions for 2018 tax years. The IDS must be lodged by businesses that provide a response at the trigger questions of the relevant
See MoreGermany: The CJEU decision permits deviations from the arm’s length principle
On 31 May 2018, the Court of Justice of the European Union (CJEU) issued its decision in the case of: C-382/16 Hornbach-Baumarkt that a parent company’s position as a shareholder of a non-resident company may be taken into account in
See MoreNetherlands publishes new transfer pricing decree
The Dutch Ministry of Finance published a new transfer pricing decree nr. 2018-6865 on 22 April 2018, which was published in the State Gazette on 11 May 2018. The Decree is in line with the outcomes of the Base Erosion and Profit Shifting (BEPS)
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