Colombia enacts amended tax reform law
On 27 December 2019, Colombia has enacted tax reform law (Law 2010), which replaces the previous tax reform (Law 1943). The previous Law was held to be unconstitutional by the Constitutional Court on 16 October 2019 but was allowed to be in force
See MoreTransfer Pricing Brief: January 2020
BrazilDispute resolution-Best practices: The OECD peer review report regarding Brazil published on 28 November 2019 notes that Brazil has concluded 35 double tax treaties all of which contain a provision relating to the mutual agreement
See MoreGermany publishes draft bill to implements ATAD hybrid mismatch rules
On 10 December 2019, the German Ministry of Finance issued a draft bill to implement the anti-tax avoidance directive (ATAD) including Hybrid mismatch rules. The hybrid mismatch rules will apply from 1 January 2020 to address double deduction
See MoreBulgaria: Parliament accepts tax loss carry forward for CFC
The Parliament recently approved tax loss carry forward rules for controlled foreign companies (CFC). It was stated that the losses may be carried forward for up to five years and should be applied to tax losses incurred after December 31,
See MoreGermany gazettes a law implementing EU directive on cross-border tax planning arrangements
On 30 December 2019, the German Official Gazette published a law implementing EU directive on reporting requirements for cross-border tax planning arrangements. The directive commonly referred to as DAC 6 which require the taxpayers and
See MoreEcuador: Government publishes tax reform for 2020
On 31 December 2019, the Government published tax reform 2020 through Law of Simplicity and Tax Progressivity (Law No. SAN-2019-1270) in the Official Gazette. The Law effects from 1 January 2020. Some of the key provisions are given
See MoreFinland: President sign the law to implement the EU directive on hybrid mismatch rules
On 30 December 2019, the President of Finland signed the Law 1567/2019 that provides for the implementation of the hybrid mismatch rules of the Anti-Tax Avoidance Directive, as amended by Council Directive (EU) 2017/952 (ATAD2). The hybrid
See MoreMalta publishes Regulation to implement DAC6 reporting requirements
On 17 December 2019, Malta published Cooperation with Other Jurisdictions on Tax Matters (Amendment) Regulations 2019 through Legal Notice 342 of 2019. The Amendments transpose the provisions of Council Directive 2018/822 of 25 May 2018 amending
See MoreDenmark: MLI enters into force
On 1 January 2020, the Multilateral Convention to Implement Tax Treaty Related Measures to Prevent Base Erosion and Profit Shifting (MLI) entered into force for Denmark. On 30 September 2019, Denmark deposited its instrument of ratification for the
See MoreFinland adopts EU directive on cross-border tax planning arrangements
On 30 December 2019, Finnish President approved the Law 1559/2019 for the implementation of Council Directive (EU) 2018/822 of 25 May 2018 (DAC6) on reporting requirements for cross-border tax planning arrangements. Under DAC6, taxpayers
See MoreHong Kong: IRD extends CbC reporting deadline for local filing
On 18 December 2019, Inland Revenue Department announced an extension to the due date for local filing of some country-by-country tax reports. The local filing requirement applies to a relevant accounting period beginning on or after 1 January
See MoreDTA between Ecuador and Japan enters into force
On 28 December 2019, the Double Taxation Agreement (DTA) between Ecuador and Japan was entered into force and applies from 1 January 2020. The DTA contains Dividends rate 5%, Interest rate 10%, and Royalties rate
See MoreAustria releases digital services tax guide
On 20 December 2019, Finance Ministry published guide regarding digital service tax. Under the guide, 5% tax will be applicable for advertisements on a digital interface. Accordingly, this guide helps to know of how to submit or payment digital
See MoreKazakhstan: State Revenue Committee clarifies statute of limitation for tax violations
Recently, the State Revenue Committee (SRC) described that the statute of limitations period in case of tax violations is 3 years instead of 5 years as from 1 January 2020. Before 1st January 2020, however, the statute of limitation period remains
See MoreEcuador: President made objections on second tax reform bill
On 14 December 2019, the President, Moreno, made objections on the second tax reform bill approved by the National Assembly. Accordingly, he proposed to limit the application of the thin-capitalization rules to inter-company loans. Accordingly,
See MorePanama extends CbC reporting deadline and notification
On 27 December 2019, Directorate General of Revenue of Panama has issued Resolution No. 201-9116 and 201-9117, with effect from the date of publication. Resolution No. 201-9116 extends the filing of Country by Country (CbC) reporting until 31
See MoreUkraine: National Bank reduces the interest rate from December 2019
On 12 December 2019, the National Bank of Ukraine decided to reduce its key policy rate from 15.5% to 13.5% per annum with effect from 13 December 2019. The interest rate has a tax effect on the late tax payment interest and
See MoreMalaysia: IRB releases Transfer Pricing audit framework for 2019
On 15 December 2019, the Malaysian Inland Revenue Board (“MIRB”) published the TP audit framework (2019). The Transfer Pricing Audit Framework 2019 is effective from 15 December 2019 and replaces the Transfer Pricing Audit Framework 2013 which
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