Ukraine: President signs law to implement BEPS and other provisions
On 21 May 2020, the President of Ukraine signed Law No. 466-IX (Draft Law No.1210) “On Amendments to the Tax Code of Ukraine on Improvement of Tax Administration, Elimination of Technical and Logical Inconsistencies in Tax Legislation", which was
See MoreLuxembourg: 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 MoreChile: Government publishes Tax Reform Law
On 24 February 2020, Government published Law No. 21.210 in the Official Gazette and effects as from 1 January 2020. This Law was approved by the Senate on 29 January 2020. The tax reform Law includes: Corporate income tax The Law includes a
See MoreChile: Senate approves Tax Reform Bill
On 29 January 2020, the Senate approved a Tax Reform Bill. Once in force, the proposed measures will generally apply as from 1 January 2020, except the VAT requirements for digital services, which will be implemented three months after the law is
See MoreQatar publishes new regulations to amend income tax law
On 11 December 2019, Qatar published Executive regulations 39/2019 in the Official Gazette, introduced new Income Tax Law No. 24 of 2018. The new regulations are generally effective from 12 December 2019. Key features of the new regulations
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
See MoreDenmark publishes the Bill no. L 48 on international taxation
On 6 November 2019, the Danish Minister of Taxation published Bill no. L 48 on international taxation. The bill updated the existing PE (permanent establishment) rules, CFC rules and strengthen the Transfer pricing (TP) rules. PE rules: The
See MoreNew Zealand: Inland Revenue updates its compliance focus on MNEs
On 1 November 2019, the Inland Revenue has published a document setting out its compliance focus in respect of Multinational Enterprises (MNEs). The document aimed to make tax compliance more transparent for businesses and provide transparency and
See MoreColombia: MinHacienda issues decree on taxation of investment funds and PEs
On October 29, the Colombian Ministry of Finance and Public Credit (MinHacienda) has issued Decree 1973, which clarified measures regarding the taxation of private equity funds and collective investment funds and rules on the attribution of income
See MoreMexico: Congress approves tax reform package for 2020
On 30 October 2019, Mexico’s Congress has approved the tax reform for 2020 which was presented by President Andrés Manuel López Obrador’s on September 8, 2019. The Reform incorporates fundamentals of the Base Erosion and Profit Shifting
See MoreUkraine: STS clarifies on determination of profits attributable to PE
The State Tax Service (STS) of Ukraine issued Letter No. 353/ІPK/15-32-05-04-02-15 of 25 September 2019 regarding determination of profits attributable to permanent establishment (PE). Permanent establishment (PE) will be recognized as an
See MoreIndia: ITAT ruled that the Liaison Office of Hitachi constitutes a PE
On 17 September 2019, the Delhi Bench of the Income Tax Appellate Tribunal (ITAT) in the case of: Hitachi High Technologies Singapore Pte Ltd vs. DCIT , held that a Liaison Office (LO) of Hitachi Technologies Singapore Pte Limited constituted a
See MoreNetherlands: Budget proposal for 2020
On 17 September 2019, the Dutch Government published the 2020 budget proposals, which includes the Tax Plan for 2020. The 2020 Tax Plan package consists of the following six bills: the 2020 Tax Plan Bill;the Other 2020 Tax Measures
See MoreDenmark: Draft bill on international taxation submits for public comments
On 12 September 2019, the Ministry of Taxes published a major bill on international taxation. The bill will be subjected to a public hearing and subsequently presented to the Danish Parliament. Interested parties can submit their comments by 10
See MoreMexico: Tax reform proposal in economic package 2020
On 8 September 2019, Mexican president Andrés Manuel López Obrador’s presented Economic Package for the fiscal year 2020 to Congress. The economic package proposed following tax reform measures: Transparent Entities International
See MoreIndonesia: Finance Minister declares tax reform plan
On 3 September 2019, the Minister of Finance, Sri Mulyani Indrawati, announced Government’s tax reform plan through a draft bill. The draft bill proposed following measures: Gradual decrease in corporate rate from 25% to 20% starting from
See MoreHong Kong issues practice note in the methodology for attributing profits to PEs
On 19 July 2019, the Inland Revenue Department (IRD) released Departmental Interpretation and Practice Note 60 (DIPN 60) which explains the concept of permanent establishment (PE) and the methodology for attributing profits to Hong Kong
See MoreVietnam: NA approves a new taxation regime for Foreign Service providers
On 13 June 2019, the National Assembly (NA) approved the Law on Tax Administration (amended changes). The law introduced a new taxation regime for Foreign Service providers including e-commerce business. This law will take effect from 1 July
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