Ukraine: SFS explains about foreign exchange differences for transfer pricing purposes
Recently, the Ukraine State Fiscal Service (SFS) has explained about treatment of foreign exchange differences if controlled transactions meet the transfer pricing thresholds. Transactions are classified as controlled transactions if the annual
See MoreSOUTH KOREA: National Assembly approves Multilateral Instrument (MLI)
On 10 December 2019, South Korea's National Assembly has approved multilateral convention to implement tax treaty related measures to prevent Base Erosion and Profit Shifting (MLI). After the ratification process, South Korea will need to deposit
See MoreNetherlands approves Tax Plan 2020
The Dutch Ministry of Finance has announced that the Senate has approved the 2020 Tax Plan on 17 December 2019; however the Dutch Government published the 2020 budget proposals on 17 September 2019. Some of the key changes from 1 January 2020
See MoreArgentina: AFIP declares further extensions to TP filing deadlines
On 16 December 2019, the Tax Authority (AFIP) announced further extensions to timeline to transfer pricing (TP) filing returns for the financial years ending on December 31, 2018. Previously, under General Resolution 4538/2019 of 30 July 2019
See MoreThailand: 15% withholding tax on interest payment
On 6 December 2019, Thailand has published Ministerial Regulation No. 353 in the Official Gazette regarding withholding tax (WHT) on interest payments to a resident mutual fund that required deducting 15% WHT. The WHT amount should remit to the
See MoreColombia: Congress approves new tax reform bill in first debate
On 3 December 2019, the Colombia Congress has approved new tax reform bill 2019 (Law No. 1943 of 2018) in first debate. The Colombian Government submitted the new tax reform bill to Congress on 22 October 2019 due to procedural flaws as stated
See MoreKazakhstan: Government extends deadline for new VAT obligations on digital service
On 6 November 2019, the government announced the extension of the deadline for applying VAT obligations. The new deadline is due on January 1, 2021, instead of January 1, 2020. Recently, the State Revenue Committee has proposed the introduction of
See MoreArgentina: Executive Power publishes Executive Branch Decree 862/2019
On 9th December 2019, the Executive Power published Executive Branch Decree 862/2019 in the Official Gazette, which approves a new revised text of the regulatory decree of the Income Tax Act and incorporated provisions that were contained in
See MoreAlgeria: President seals Finance Act 2020
The president of Algeria, Abdelkader Bensalah, signed the Finance Act 2020 into Law, on 11 December 2019, during a Council of Ministers he chaired. The Law includes tax incentives like profit tax and VAT exemptions for start-ups corporations and
See MoreIndonesia: Tax dispute resolution peer review report
On 28 November 2019 the OECD published a stage 1 peer review report commenting on Indonesia’s compliance with the minimum standard on tax dispute resolution under Action 14 of the project on base erosion and profit shifting (BEPS). The
See MoreUS: IRS issues final regulations on the base erosion and anti-abuse tax
On 2 December 2019, the Internal Revenue Service (IRS) issued final regulations and proposed regulations on the base erosion and anti-abuse tax. The Tax Cuts and Jobs Act (TCJA) made major changes to the tax law including revamping the U.S.
See MoreMexico implements economic package 2020
On 9 December 2019, Mexico has published a decree to implement economic package 2020 which was approved by Mexican Congress on 30 October 2019. This Decree will enter into force on January 1, 2020. The economic package consists of the following
See MoreUS: IRS publishes interest rate on overpaid and underpaid for first quarter of 2020
On 6 December 2019, The Internal Revenue Service announced interest rates for overpayments and underpayments that will remain the same for the calendar quarter beginning January 1, 2020. Accordingly, 5% for overpayments (4% in the case of a
See MoreSlovenia publishes guidance on the latest amendments to the CITA
On 2 December 2019, the tax authority has published guidance regarding the latest amendments to the Corporate Income Tax Act (CITA). The guidance also provides for a detailed description about implementation of the hybrid mismatch rules of the EU
See MoreSaudi Arabia introduces E-Service for CbC reporting
Recently, the General Authority of Zakat and Tax (GAZT) of Saudi Arabia have introduced E-Service for country-by-country (CbC) reporting. As per the transfer pricing Bylaws, Saudi Arabian taxpayers that are members of an MNE Group with consolidated
See MoreSerbia: Parliament amends the corporate income tax law including CbCR obligations
On 6 December 2019, the Serbian Parliament passed the legislation that amends the corporate income tax law including requirements for country-by-country (CbC) reporting of controlled transactions within a corporate group. The Law is published in
See MoreNew Zealand: Inland Revenue issues updated information on R&D tax incentives
On 29 November 2019, Inland Revenue of New Zealand has issued updated research and development (R&D) information and draft guidance on the latest proposals. The R&D tax incentives are included in the Taxation (KiwiSaver, Student Loans, and
See MoreTaiwan: MOF announces safe harbor rules for CbC report
On 10 December 2019, the Ministry of Finance (MOF) issued tax ruling no. 10804651540 providing exemption from CbC reporting for Taiwan entities under a MNE Group headquartered outside Taiwan. The safe harbor exemption guidance was issued in late
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