Colombia: 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
See MoreCzech 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
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