Portugal legislates the EU ATAD into domestic law
On 3 May 2019, Portugal published Law n. 32/2019 in the Official Journal which introduced amendments to the Portuguese Tax Law in line with the European Union (EU) Anti-Tax Avoidance Directive (ATAD) provisions. The law amends the following
See MoreIndonesia: MOF publishes regulations on permanent establishment’s rules
On 1 April 2019, the Minister of Finance (MoF) of Indonesia Published Regulation No. 35 / PMK.03 / 2019, on what constitutes a permanent establishment (PE).The main measures contain that are: According to the Regulation (PMK-35), the following
See MoreIndia: CBDT invites public comments on proposal to amend rules for profit attribution to PE
On 18 April 2019, the Central Board of Direct Taxes (CBDT) released the Committee’s report on profit attribution to a permanent establishment (PE) in India for public consultation, specifically requesting for comments on the conclusions and
See MoreUkraine: SFS clarifies controlled transactions between a non-resident and its PE in Ukraine
On 19 April 2019, the State Fiscal Service (SFS) of Ukraine published a guidance letter 1723/6/99-99-15-02-02-15/IPK on the treatment of transactions between a non-resident and its permanent establishment (PE) in Ukraine as controlled for transfer
See MoreGreece revises the law on setting up branches with new incentives
On 1 April 2019, the Greek Parliament passed a new bill (Law 4605/2019 ) which includes amendments to Law 89/1967 on the establishment of branches in Greece by foreign companies, including in relation to allowed business activities and incentives
See MoreIndia: ITAT ruled that the income which is deemed to accrue or arise in India must have a territorial nexus
Recently, the Mumbai Bench of the Income-tax Appellate Tribunal (ITAT) in the case of: Fox International Channel Asia Pacific Ltd v. DCIT (ITA No.1947/Mum/2015) regarding the taxability of agency commission relating to the services rendered outside
See MoreLuxembourg: Tax Authority clarifies the new Permanent Establishment definition
On 22 February 2019, Luxembourg tax authorities issued a new circular (No.19) that clarifies recently added the new Permanent Establishment (PE) definition as set forth in article 16(5) of the Tax Adaptation Law (StAnpG). Under the new paragraph,
See MoreCosta Rica: MOF publishes resolution on tax residence certificates
On 19 February 2019, Costa Rica's Ministry of Finance (MOF) published a Resolution (was first published in the Official Gazette on 4 February 2019), which provides rules on the determination of tax residence and the issuance of residence
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 MoreQatar legislates new Income Tax Law
On 17 January 2019, Qatar's new Income Tax Law (Law 24 of 2018) was published in the Official Gazette and replaced the previous Law 21 of 2009, and is effective from 13 December 2018. The main features of the new law are summarized in below: The
See MorePuerto Rico enacts the tax reform law
On 10 December 2018, Puerto Rico enacted Bill No. 1544 as Law No. 257 of 10 December 2018. The law includes numerous amendments to the Puerto Rico Internal Revenue Code of 2011 (PR Code). The changes are to generally apply for periods beginning
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 MoreKorea Rep. enacts tax reform bill for 2019
On 24 December 2018, Korea enacted the 2019 tax reform bill after it was passed by Korea’s National Assembly on 8 December 2018. The 2019 Tax Reform also includes provisions in line with the OECD BEPS Action Plan 7 among others. The 2019 Tax
See MoreGreece plans to cut corporate tax in 2020
On 14 December 2018, the Greek parliament approved the gradual reduction of the corporate income tax (CIT) rate over the next four years, under proposals announced in September. The property tax will be reduced by 30% to 50%. Under the changes, the
See MoreArgentina: Taxpayers wait for enactment of draft decree no. 1112/2017
Government has released a draft decree No.1112/2017 for tax reform Law 27430 on December 29, 2017, but it has not officially published yet. This decree includes transfer pricing aspects, permanent establishment (PE) rules, restriction on interest
See MoreNorway: Finance Minister presents National Budget 2019
The Minister of Finance, Siv Jensen, presented the draft National Budget 2019 on October 8, 2018 to the Parliament. The presentation of the budget will be followed by a cycle of parliamentary hearings and debates on the budget, which will last until
See MorePeru introduces GAAR, new thin capitalization rule, definition of PE, and Other Changes
On 13 September 2018, the Peruvian government has published Legislative Decree No. 1422 and Legislative Decree No. 1424, which include measures for the implementation of the General Anti-Avoidance Rule (GAAR), new thin capitalization and interest
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