Russia: Parliament approves law on submission of CbC reports
On 7 June 2019, the Russian parliament passed Law No. 125-FZ in the Official Gazette. The Act amends Article 105.16.3 of the Tax Code on the submission of country-by-country (CbC) reports by multinationals (MNE). The amendments extend the list
See MoreAustralia provides additional 15 days for CbC statement lodgment
The Australian Taxation Office (ATO) has provided additional 15 days for the lodgment of CbC statements (Local File, Master File, CbC report) with 30 June 2019 due date because of technical issues. This additional time will apply automatically
See MoreChina updates expense deduction limit for insurance sector
China's Ministry of Finance (MoF) has published Announcement No. 72 of 2019 regarding pre-tax deduction policy for insurance enterprise handling fees and commission expenses. The announcement provides that insurance companies may deduct up to
See MoreCanada: Federal budget 2019 bill enacted
On 21 June 2019, Canada’s corporate income tax measures as included in three federal bills are deemed to be substantially enacted. The summary corporate tax measures are following: Increasing 15% tax credit for mineral
See MorePoland publishes explanatory note addressing transfer pricing comparability analyses
On 19 June 2019, Poland Ministry of Finance published an explanatory note addressing transfer pricing comparability analyses. Accordingly, database for comparables could be selected locally, regionally, or even globally by considering
See MorePortugal approves MLI
On 21 June 2019, the Portugal's parliament approved the resolution for the ratification of the Multilateral Convention to Implement Tax Treaty Related Measures to Prevent Base Erosion and Profit Shifting (MLI). After the ratification process,
See MoreSouth Africa: Tax benefits for investors through Section 12J VCC regime
In 2009 Government implemented a tax incentive for investors in privately owned entrepreneurial businesses in South Africa to assist small and medium sized enterprises (SMEs) with access to equity finance. Individuals, companies and trusts (any SA
See MoreIndonesia: MOF proposes draft amendments to the SEZ scheme and tax cuts
The Indonesian Ministry of Finance (MoF) published two announcements on June 17 and 20 June 2019. The ministry is reviewing draft amendments to the Special Economic Zones (SEZ) regime and tax cuts for specific sectors. SEZ regime: Under this
See MoreUruguay: New incentive for software development
Uruguay has published Decree No 96/2019 of 22 April 2019 amending exemption incentive for software development with effect from 1 January 2018 to comply with BEPS Action 5. The decree applies retroactively from 1 January 2018. The Decree
See MoreRussia proposes Transfer Pricing and MAP-related changes
The Russian Ministry of Finance has proposed some transfer pricing amendments (Draft legislation No. 720839-7) and submitted them to the State Duma for approval (preliminary examination of the draft law submitted to the State Duma). The draft law
See MoreSaudi Arabia: GAZT holds seminar to simplify the transfer pricing regulations
On 17 June 2019, the General Authority of Zakat and Tax (GAZT) of Saudi Arabia has organized a transfer pricing seminar in Riyadh to simplify the key areas of the transfer pricing (TP) regulations published on 15 February 2019 and to address
See MoreNetherlands: Consultation on tax group regime
The Finance Ministry of the Netherlands has announced the launch of a public consultation on the design of a new corporate tax group regime to replace the current fiscal unity regime. The consultation includes four possible
See MoreSlovak Republic approves a draft law to update income tax act
On 29 May 2019, the Slovak government approved a draft Law to update the Income Tax Act. The draft law proposes the implementation of Directive 2017/952 amending Directive 2016/1164 as regards hybrid mismatches with other countries. It also
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 MoreRussia deposits ratification instrument for MLI
On 18 June 2019, the Russian Federation has deposited its instrument of ratification for the Multilateral Convention to Implement Tax Treaty Related Measures to Prevent Base Erosion and Profit Shifting (MLI). According to the date of deposit,
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
See MoreKenya: Finance Minister proposes Budget for the Financial Year 2019/20
On 13 June 2019, the Finance Minister, Henry Rotich of Kenya presented the budget for 2019/20 to the parliament. The budget includes the following tax related measures: Capital Gains Tax is proposed to be increased from 5% to 12.5%. There is
See MoreColombia: DIAN publishes procedures to submit the TP return, Master file, Local file and CbC report
On 22 May 2019, the Colombian tax authority (DIAN) published regulations for the submission of the Local file and Master file, the Transfer pricing (TP) return, and the Country-by-Country (CbC) report notification corresponding to the 2018 tax year
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