Romania implements EU Directive on Dispute Resolution
On 22 August 2019, Romania has published Ordinance No. 19 in the Official Gazette, which implemented the EU Tax Dispute Resolution Directive 2017/1852 in the tax procedure code (Law no. 207/2016). The provisions apply to complaints submitted
See MoreRussia reduces the Interest rate from September 2019
On 6 September 2019, the Russian Central Bank announced the decision to reduce the key rate from 7.25% to 7.00% with effect from 9 September 2019. For tax purposes, the key rate is important in relation to the safe harbor rates for interest
See MoreIreland: 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 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 MoreChina introduces several incentives for Lingang in Shanghai FTZ
On 6 August 2019,, China announced that it has added the Lingang area to the China (Shanghai) Pilot Free Trade Zone (FTZ) to enhance investment and advance trade liberalization with plans to replicate the concept nationwide, senior officials said.
See MoreFrance: Tax Authority issues a Ruling on interest deduction
The tax authority issued a ruling regarding the deductibility of interest paid to a related Belgian company benefiting from the notional interest regime. On 4 September 2019, the French General Directorate of Public Finance clarified that tax
See MoreWorld Tax Brief: September 2019
TaiwanBusiness income taxation: On 26 August 2019, the Taiwan National Tax Bureau for the Northern Area (NTBNA) published a notice for domestic companies. The Notice clarifies that domestic companies purchasing e-services from a foreign
See MoreTransfer Pricing Brief: September 2019
AustraliaFinancial services: On 28 August 2019, the Australian Taxation Office (ATO) published draft Practical Compliance Guideline PCG 2019/D3, which sets out the proposed compliance approach for the use of the arm’s-length debt test (ALDT)
See MoreCosta Rica: Government announces the budget for 2020
On 30 August 2019, Costa Rican government presented the 2020 budget to the Legislative Assembly which is 4.3% lower than in 2019, thus representing the largest spending reduction in recent years. The tax reform adopted by Congress in December is
See MoreColombia: DIAN issues resolution on MAP
On 13 August 2019, the Colombian National Tax Authority (Dirección de Impuestos y Aduanas Nacionales, DIAN) has published Resolution No. 000053 in the official gazette which establishes Mutual Agreement Procedure (MAP) to avoid double taxation and
See MoreMalaysia releases digital services tax guide
On 20 August 2019, the Royal Malaysian Customs Department published a service tax guide on digital services. The purpose of the guide is to provide a general understanding of the relevant treatment under Sales Tax and Services Tax Legislation and
See MoreUS: IRS publishes interest rates on overpaid and underpaid tax for the 4th quarter of 2019
On 28 August 2019, the Internal Revenue Service announced interest rates on overpaid and underpaid tax for the calendar quarter beginning 1 October 2019 that will remain the same, as they were in the prior quarter. The rates will be 5% for
See MoreLuxembourg implements EU Directive on mandatory disclosure rules
On 8 August 2019, the Luxembourg Government submitted draft law 7465 to the parliament to implement the European Union (EU) mandatory disclosure rules and exchange of information on cross-border tax arrangements (DAC6 or the
See MoreTaiwan: NTBNA issues notice on business tax on e-services purchase
On 26 August 2019, Taiwan's National Taxation Bureau of the Northern Area (NTBNA) has issued a notice for domestic entities to pay business tax on e-services purchased from foreign providers. The notice clarifies about domestic business entity that
See MoreSlovenia implements the mandatory disclosure rules
On 28 May 2019, the Slovenian Parliament has approved the EU Directive on the mandatory disclosure and exchange of cross-border tax arrangements (DAC6). The final Slovenian Mandatory Disclosure Rules legislation is significantly aligned to the
See MorePoland: Ministry of Finance publishes a draft bill to implement EU ATAD 2 anti-hybrid measures
On 23 August 2019, the Poland Ministry of Finance released a draft bill outlining several provisions to implement EU ATAD 2 anti-hybrid measures. The main purpose of implementing the anti-hybrid measures is to counteract the situation of double
See MoreUS: Court of Appeals approves Tax Court’s decision in Transfer Pricing case
On 16 August 2019, the U.S. Court of Appeals for the Ninth Circuit in the case of: Amazon.com, Inc. v. Commissioner, 148 T.C. 108 (2017) issued a decision in favor of Amazon concerning the regulatory definition of intangible assets and the
See MoreCosta Rica publishes resolutions on returns related to capital income, capital gains and others
On 30 July 2019, Costa Rican tax administration released a resolutions amending withholding tax forms and procedures on interest, dividends, and foreign income for the tax period July 2019 forward. The resolution provides several measures
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