Luxembourg: Tax Authority issues new guidance on CFC rules
On 4 March 2020, the Luxembourg Tax Authority has issued Circular n°164ter/1 on the controlled foreign corporation (CFC) rules. Luxembourg enacted CFC rules as part of the implementation of the EU Anti-Tax Avoidance Directive (ATAD) on 21 December
See MoreSerbia: Ministry of Finance publishes safe harbor interest rates for 2020
The Serbian ministry of finance has published the Rulebook on arm’s length interest rates that are applicable for 2020, which apply to interest rates on loans and credits between associated parties. The Rulebook was published in the Official
See MorePeru: SUNAT provides a list of high-risk tax planning schemes regarding GAAR
On 5 February 2020, the Peruvian Tax Administration (SUNAT) has published first version of the list of high-risk tax planning schemes regarding General Anti-Avoidance Rule (GAAR). The list contains the following five tax planning
See MoreDominican Republic: DGII publishes list of territories not considered tax heavens
The Directorate General of Internal Revenue (DGII) issued Notice 10-20 regarding an updated list of States that are not considered tax heaven or preferential tax regimes. The list includes the following territories: Antigua and Barbuda,
See MoreColombia: DIAN issues new guidelines for GAAR
On 15 January 2020, Colombian tax authority (DIAN) has published Executive Order No. 4 of 7 January 2020 in the official gazette where DIAN clarifies the application of General Anti-Avoidance Rule (GAAR). The GAAR provisions are contained in
See MoreRomania enacts EU mandatory disclosure regime (DAC6)
On 28 January 2020, the Government of Romania has published Ordinance no. 5 of 28 January 2020 in the Official Gazette for the implementation of Council Directive (EU) 2018/822 of 25 May 2018 (DAC6) on reportable cross-border tax planning
See MoreFrance: Tax authority publishes guidelines on the new provisions on abuse of law
On 31 January 2020, the tax authority published guidelines regarding the application of the new general anti-abuse rules (GAAR). This guide provides an extension of Article 6 of the EU Anti-Tax Avoidance Directive 2016/1164. It may also apply in
See MoreBosnia and Herzegovina: Government adopts Law on Profit Tax
On 16 January 2020, Government adopted the amendment in Law on Profit Tax. The Law proposed to exclude leasing companies from the interest deduction limitations provisions. On the other hand, this Law stated that income statements are not necessary
See MoreUkraine: Parliament adopts draft law on amendments to the Tax Code
On 16 January 2020, the Ukrainian Parliament adopted Law No 1210 on amendments to the Tax Code of Ukraine with regard to improvement of tax administration, elimination of technical and logical discrepancies in tax legislation. The important
See MoreSouth Africa: President signs five revenue related Bills into Law
On 21 January 2020, the National Assembly released a Media Statement, which provides that on 13 January 2020, President, Cyril Ramaphosa, signed into law five different revenue related bills. These bills, which have now been promulgated include the
See MoreNorway: The new statutory GAAR enter into force from 1 January 2020
Norway introduced a new general anti-avoidance rule (GAAR) with effect from 1 January 2020. The new statutory GAAR is similar to the previous GAAR in terms of scope, content and threshold for use with a few exceptions. The statutory GAAR will
See MoreNigeria: President signs Finance Bill 2019 into Law
On 13 January 2020, the President, Muhammadu Buhari, signed the 2019 Finance bill into law. It was submitted alongside the 2020 budget to the National Assembly. The new law contains over 90 changes to 7 different tax laws. Corporate income
See MoreBelgium enacts EU mandatory disclosure regime (DAC6)
On 12 December 2019, the Belgian Parliament adopted legislation implementing the EU Directive on the mandatory disclosure and exchange of cross-border tax arrangements (DAC6) and it was published in the Official Gazette on 30 December 2019. Under
See MoreBulgaria: Parliament accepts tax loss carry forward for CFC
The Parliament recently approved tax loss carry forward rules for controlled foreign companies (CFC). It was stated that the losses may be carried forward for up to five years and should be applied to tax losses incurred after December 31,
See MoreEcuador: President made objections on second tax reform bill
On 14 December 2019, the President, Moreno, made objections on the second tax reform bill approved by the National Assembly. Accordingly, he proposed to limit the application of the thin-capitalization rules to inter-company loans. Accordingly,
See MoreOECD: Report on Transfer Pricing in Brazil
On 18 December 2019 the OECD issued a report entitled Transfer Pricing in Brazil: Towards Convergence with the OECD Standard. This examines the differences between Brazil’s transfer pricing rules and the OECD transfer pricing guidelines with a
See MoreArgentina: Executive Power publishes Executive Branch Decree 862/2019
On 9th December 2019, the Executive Power published Executive Branch Decree 862/2019 in the Official Gazette, which approves a new revised text of the regulatory decree of the Income Tax Act and incorporated provisions that were contained in
See MoreMexico implements economic package 2020
On 9 December 2019, Mexico has published a decree to implement economic package 2020 which was approved by Mexican Congress on 30 October 2019. This Decree will enter into force on January 1, 2020. The economic package consists of the following
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