Ireland: Finance Department publishes feedback statement regarding TP rules
In February 2019, the Finance Department carried out a public consultation on Ireland’s transfer pricing rules indicating the intended direction in respect of certain recommendations contained in the Coffey Review and seeking stakeholders
See MoreChile: Chamber of Deputies approves tax reform bill
On 23 August 2019, the tax reform Bill was passed by the Chamber of Deputies. The tax changes in the reform bill include: a new definition of permanent establishmentsa new concept for tax deductible expenses;the introduction of green taxes; anda
See MoreRussia updates the CFC notification form
On 1 August 2019, the Federal Tax Service (FTS) has approved the amended CFC and the filing procedure in electronic form with an order of 5 July 2019 No. MMV-7-13 / 338. This regulation extends the list of information on foreign organizations
See MoreBulgaria modifies the CFC Rules
The recently published Bulgarian Law amending and supplementing the Tax and Social Security Act includes some modifications and explanations of the rules for Controlled Foreign Companies (CFC), which were introduced with effect from 1 January 2019,
See MorePeru: SUNAT issues resolutions on GAAR
On 31 July 2019, the Peruvian Tax Administration (SUNAT) published two resolutions (152-2019/SUNAT and 153-2019/SUNAT) regarding general anti-avoidance rule (GAAR) in the Official Journal. The two resolutions are summarized below: Resolution
See MoreAustralia introduces a bill to amend thin capitalization rules
On 4 July 2019, the Treasury Laws Amendment (Making Sure Multinationals Pay Their Fair Share of Tax in Australia and Other Measures) Bill 2019 was introduced in the Australian House of Representatives. The purpose of the Treasury Laws
See MoreIreland introduces new Guidance on CFC rules
On 22 July 2019, Ireland has published a new Tax and Duty Manual, Part 35b-01-01 in respect of the Controlled Foreign Company (CFC) rules, that were introduced by Finance Act 2018 and take effect from 1 January 2019. The manual provides an
See MoreColombia publishes new thin capitalization rule
On 26 June 2019, the Government of Colombia published a Decree 1146 of 2019, concerning the new thin capitalization rules which amended the previous law 1943 of 2018. The new Decree 1146 of 2019 includes the following measures: The thin
See MoreOECD and Brazil: Report on project to align transfer pricing rules with OECD standards
On 7 July 2019 the OECD and Brazil’s tax administration (RFB) published a report on the results of the work programme launched in February 2018 to analyse Brazil's transfer pricing framework and the similarities and divergences between the
See MoreIndonesia: 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
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