Australia: ATO compliance approach to the arm’s length debt test
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) for the purposes of
See MoreSingapore REIT eligible for WHT exemption in Italy
On 26 August 2019, the Italian tax authority has published Ruling No. 345 regarding the eligibility of a real estate investment trust (REIT) established in Singapore for the withholding tax (WHT) exemption on income derived through a
See MoreNorway launches a consultation proposal on changes to the group contribution rules
On 13 August 2019, the Ministry of Finance published a proposal to amend the group contribution rules regarding EFTA Court rule of 13th September 2017, which found that Norway's rule violated freedom of establishment rights in cases where there is
See MoreFinland: Ministry of Finance announces the budget proposal for 2020
On 16 August 2019, the Finnish Ministry of Finance announced the proposal for the 2020 budget package. The proposal includes following tax measures: A gradual increase tobacco tax by EUR 200 million over the period 2020 to 2023An increase in
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 MoreUkraine issues guidance on transactions between non-resident and its representative offices
On 16 August 2019, the Ministry of Finance issued Order No. 345 providing guidelines on transfer pricing arrangements for transactions between non-residents and their representative offices and permanent establishments in Ukraine. The Order
See MoreIndia: CBDT issues FAQs on filling of ITR forms for AY 2019-20
On 8 August 2019, the Central Board of Direct Taxes (CBDT) has issued Circular No. 18, which includes frequently asked questions (FAQs) on the completion of income tax return (ITR) forms for Assessment Year (AY) 2019-20. The FAQs are aimed
See MoreItaly updates CbC reporting requirements
On 8 August 2019, Italy has published the Ministerial Decree in the Official Gazette amending the Ministerial Decree of 23 February 2017 regarding Country-by-Country reporting (CbCR). The Decree amends Article no. 7 on the use of CbC
See MoreIndonesia: President announces budget for 2020
On 16 August 2019, Indonesian President Joko Widodo proposed a 2,528.8 trillion rupiah ($177.56 billion) budget to parliament for 2020 and expected to set a higher target for economic growth. Budget 2020 includes a new super deduction for
See MoreIsrael publishes transfer pricing form for 2019
The tax administration of Israel updated transfer pricing declaration Form-1385, which is a declaration by entities regarding their intercompany transactions with related parties. The tax administration of Israel recently announced that the use
See MoreSaudi Arabia: GAZT publishes Tax Ruling Requests guide
Recently, the General Authority of Zakat and Tax (GAZT) of Saudi Arabia published the English version of Tax Ruling Requests guide. The tax ruling guide includes the following measures: An applicant can apply for a Ruling when it is unsure
See MoreDenmark: Tax Agency allows for the opportunity to re-open certain transfer pricing cases
On 12 July 2019 the Danish Tax Agency issued a new decree (SKM2019.374.SKTtST) regarding transfer pricing documentation in response to the Supreme Court’s decision in the Microsoft case. The decree allows some taxpayers to reopen Denmark transfer
See MoreUS: IRS withdraws “Altera Memo” directive on cost-sharing arrangements
On 5 August 2019, the U.S. IRS published a memorandum dated 31 July 2019 on the formal withdraw of Directive LB&I-04-0118-005. Directive LB&I-04-0118-005 was issued on 12 January 2018 and provided instructions for examiners on transfer
See MoreLithuania further changes TP documentation rules
On 12 August 2019, the tax authorities released the new transfer pricing (TP) rules, which will apply from 2019, in addition to the previously announced new TP rules. The tax authorities also include the following TP measures: Abolishing the
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 MorePhilippines: House Committee approves bill on corporate income tax reform
The House Committee on Ways and Means has approved the administration’s second tax reform package (Corporate Income Tax and Incentives Reform Act (CITIRA)) on 14 August 2019, which aims to reduce corporate income taxes (CIT) and rationalize
See MoreDominican Republic: Government introduces new simplified tax regime for small taxpayers
The Dominican Republic published Presidential Decree No. 265-19 of 1 August 2019, which introduces a new simplified tax regime (RST) for small entities. This previous simplified tax regime is canceled and RST is applicable for both legal and
See MoreMalta announces deduction rules for patent box regime
On 13 August 2019, the Government of Malta has published Legal Notice 208 of 2019 introducing ‘Patent Box Regime (Deduction) Rules, 2019’ on qualifying intellectual property (IP). The patent box regime grants additional tax deductions on income
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