Peru: Tax authority clarifies the scope of CFC rules
On 7 February 2019, the Peruvian Tax Authority published a report (097-2018-SUNAT / 7T00000) clarifying the passive net income attribution of CFC rules to its Peruvian shareholders. The Ministry of Finance simplifies the following issues in the
See MoreIreland: Public consultation on new transfer pricing regime
On 18 February 2019, Department of Finance of Ireland released the public consultation document to update transfer pricing regime, with an effective date of 1 January 2020. The consultation looks for feedback on a number of aspects of existing
See MoreOECD: Taxpayer input required for eighth batch of dispute resolution peer reviews
The OECD announced on19 February 2019 that it is currently collecting taxpayer input in preparation for the eight batch of stage 1 peer reviews in relation to improving the tax treaty dispute resolution process under Action 14 of the project on base
See MorePortugal: Parliament proposes to implements The Anti-Tax Avoidance Directive
Recently, the Portuguese Government has submitted to Parliament the Bill No.177/XIII introducing changes to the Income Tax Act to implement certain ATAD-1 rules. The bill proposed rules for the limitation of interest deductions and rules for
See MoreOECD: Comment period extended on tax challenges of digitalisation
On 19 February 2019 the OECD announced that the consultation period in relation to the public consultation document on possible solutions to the tax challenges of digitalisation has been extended to 6 March 2019. The public consultation meeting on
See MoreUK: Consultation on Plastic Packaging Tax
On 17 February 2019 the UK government issued a consultation document on the introduction of a plastic packaging tax, inviting comments from interested parties by 12 May 2019. This consultation follows a call for evidence in March 2018 which
See MoreUK: Support for Tax Capacity Building
On 19 February 2019 the UK’s Department for International Development (DFID) announced new assistance to give support to developing countries in generating greater tax revenue, tackling tax avoidance and creating a level playing field for
See MoreUK: Finance Act 2019 receives Royal Assent
The UK Finance Act 2019 received the Royal Assent on 12 February 2019. The Act includes some of the measures announced by the Chancellor in the Autumn Budget in October 2018. Annual Investment Allowance The Annual Investment Allowance (AIA) is being
See MoreSingapore presents Budget for 2019
On 18 February 2019, the Finance Minister of Singapore delivered the Budget for 2019. The main tax-related measures are summarized below: To maintain support to companies in their automation, productivity and scale-up efforts, the 100%
See MoreSaudi Arabia: GAZT approves the transfer Pricing Law
On 15 February 2019, the Board of Directors of General Authority of Zakat and Tax (GAZT) of Saudi published a resolution approving transfer pricing Bylaws as well as an additional FAQs document. The law consists of 26 articles, divided into 12
See MoreDominican Republic: DGII updates transfer pricing brochure
On 7 February 2019, The Dominican Republic’s Directorate General of Internal Revenue (DGII) published online brochure to update guidance on transfer pricing. The brochure makes a number of following changes on transfer pricing: Reporting
See MoreSweden: Proposal for the extension of the hybrid match rules submits for comments
On 1 February 2019, the Ministry of Finance has sent a memorandum on referral with a proposal to extend the so-called hybrid rules. The purpose of the rules is to prevent differences in countries legislation being used in cross-border arrangements
See MoreBelgium updates TP reporting penalties
On 8 February 2019, the Belgian Federal Public Service (SPF) Finance published Circular Letter No. 2019/C/14 regarding penalties due if a taxpayer fails to fulfill its transfer pricing (TP) reporting obligations. The Circular Letter is an annex to
See MorePortugal legislates law on automatic exchange of financial information
The Assembly of the Republic of Portugal adopted Legislative Decree 17/2019 on 14 February 2019. The law amends the current implementation of the rules governing the automatic exchange of information in tax matters under Council Directive 2014/107 /
See MoreKenya simplifies the taxation of non-tax profits distributed as dividends
On 8 February 2019, the Kenya Revenue Authority (KRA) published a notice clarifying the new measure introduced by the Finance Act, 2018. The Act introduced a new corporate rate on untaxed gains or profits from which dividends are distributed with
See MoreOECD: Consultation document on tax challenges to the digital economy
On 13 February 2019 the OECD’s Inclusive Framework published a consultation document on issues relating to the tax challenges of digitalisation of the economy. This follows the publication on 29 January 2019 of a Policy Note and the agreement of
See MoreColombia: DIAN publishes transfer pricing return and other forms for 2019
On 15 January 2019, Directorate of Taxes and National Customs (DIAN) of Colombia published Administrative Regulation 000004 of 2019 to provide the following form for filing a 2019 tax return: Informative transfer pricing return (Form 120);
See MoreBrazil: RFB updates TP rules on import transaction and commodities
On 29 January 2019, the Brazilian Federal Revenue Department (RFB) issued Normative Instruction (NI) 1870/2019 amending NI 1312/2012 effective as of calendar year 2019. The amendments are mainly related to import transaction and commodities and some
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