Denmark: Court imposes fines for not providing timely submission of TP documents
On 19 November 2018, the Danish tax authority published an overview of a decision by the Copenhagen Court on whether a company acted in a grossly negligent act for failing to submit the timely submission of transfer pricing (TP) documents and should
See MoreIMF report comments on Spain’s fiscal position
On 19 November 2018, the International Monetary Fund (IMF) issued a report following consultations with Spain under Article IV of the IMF articles of agreement. In Spain the real GDP growth is expected to decrease to 2.5% percent in 2018 and to
See MoreBrazil: Government publishes new Decree 9,580
The Government published Decree 9,580 of November 22, 2018 in the Official Gazette on November 23, 2018, which revises the previous Decree No. 3000 of 1999. The new decree compiles provisions related to personal income tax, corporate income tax and
See MoreEgypt: Ministry of Finance publishes new decree 547 outlining new updated TP guidelines
On 21 October 2018, Egyptian Ministry of Finance has issued new decree 547 providing the authority for new transfer pricing guidelines to be published. The new guidelines introduced three-tiered level of transfer pricing reports for transparency to
See MoreUruguay issues guidance of new TP documentation requirements
In October 2018, the government of Uruguay issued Decree No. 353/2018 providing regulatory guidance regarding new transfer pricing (TP) documentation requirements. The decree clarifies guidance to implement the transfer pricing documentation
See MoreSingapore: Reminder on due date for submitting CIT returns for YA 2018
The Inland Revenue Authority of Singapore has issued a reminder to companies that the corporate income tax return filing deadline for Year of Assessment (YA) 2018 is: Paper Filing: 30 Nov 2018; and E-Filing: 15 Dec 2018. E-filing of tax
See MoreDenmark: The Ministry of Finance releases the new tax limits for 2019
On 14 November 2018, the Danish Ministry of Taxation has published a tax amount limits table for 2019. The table includes various amount limits for tax purposes in relation to individual income tax, although certain other amounts are included for
See MoreBulgaria: MoF proposes new mandatory documentation rule for transfer pricing
On 5 November 2018, the Ministry of Finance (MoF) published a draft consultation, proposing new mandatory documents for transfer pricing documentation, and a penalty for failure to comply with up to 1% of the value of undocumented transactions. The
See MoreBulgaria: Parliament approves budget 2019 at first reading
On 7 November 2018, the National Assembly passed the 2019 Budget Act at first reading with 115 MPs in favor and 85 opposed. The budget proposal containing amendments to the corporate tax laws. The proposed corporate income tax amendments are
See MorePhilippines: Senate approves tax amnesty Bill No. 2059
The Senate made an announcement that it approved Senate Bill No. 2059 on November 19, 2018, which seeks to allow a one-time opportunity to settle tax obligations. This Bill grants amnesty to taxpayers who have been remiss on paying estate taxes, all
See MoreBrazil: Tax Authority describes tax treatment of international charter leasing payments
The Federal Brazilian Tax Authorities (RFB) published Solução de Consulta – Cosit 166/2018 on September 28, 2018 regarding the application of the reduced rate of 0% income withholding tax for international charter leasing payments. It states
See MoreFinland: Ministry of Finance submits a bill on changes to CFC rules to Parliament
On 1 November 2018, the Ministry of Finance submitted a bill to Parliament proposing changes to the CFC rules. Under the proposed rules, the control threshold setting the CFC status would be reduced from 50% to 25%, and the direct or indirect
See MorePeru: SUNAT extends deadline for submission of CbC report to March 2019
On 11 November 2018, Peruvian tax authorities (SUNAT) published Ruling No. 264-2018 SUNAT which extended the due date for submitting CbC report from November 2018 to March 2019 for fiscal year 2017. The extension applies to Peruvian taxpayers who
See MoreOECD: Inclusive Framework report on preferential tax regimes
On 15 November 2018 the OECD published a progress report in relation to the work by the Inclusive framework on base erosion and profit shifting (BEPS) on assessing preferential tax regimes. The Inclusive Framework is implementing the monitoring
See MoreLatvia: Parliament adopts regulation with new requirements for transfer pricing documentation
On 25 October 2018 the Parliament approved amendments to the law ‘On taxes and duties’ which introduce in Latvia the OECD format of the transfer pricing documentation. The law was published on 14 November 2018 as the official Gazette no
See MoreMalaysia: Corporate tax proposals under budget 2019
On 2 November 2018, the Malaysian Finance Minister presented his budget proposals for 2019. Summary of the main corporate tax proposals: Introduction of a Special Voluntary Disclosure Program for taxpayers to voluntarily declare any unreported
See MoreArgentina: Taxpayers wait for enactment of draft decree no. 1112/2017
Government has released a draft decree No.1112/2017 for tax reform Law 27430 on December 29, 2017, but it has not officially published yet. This decree includes transfer pricing aspects, permanent establishment (PE) rules, restriction on interest
See MoreUK: Call for evidence on amendments to tax returns
On 7 November 2018 the UK government issued a call for evidence on the amendment of tax returns. The closing date for receipt of comments is 6 February 2019. An amendment is any change made by a taxpayer to a tax return that has already been
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