Portugal: Administrative Court issued a decision on Transfer Pricing case
On 10 October 2019, in the case of : n.º 511/2018-T, the Administrative Court issued a decision on the sale of raw materials and goods by a company to related parties. In particular, concerning an undervalued controlled transaction tested using
See MoreSerbia: Parliament adopts draft bill to implement CbC reporting obligations
On 18 October 2019, the Serbian parliament accepted for consideration a bill to implement country-by-country (CbC) reporting obligations for multinational entities (MNEs). Under this ultimate parent entities of an MNE group resident in Serbia are
See MoreGhana: Finance Minister presents 2020 Budget
On 13 November 2019, Finance Minister, Mr. Ken Ofori-Atta, has presented the New Patriotic Party (NPP) government’s fourth Budget Statement and Economic Policy to Parliament which he said is focused on providing liquidity to boost
See MoreKazakhstan: Lower house of parliament approves ratification of BEPS MLI
On 30 October 2019, the lower house of Parliament (Mazhilis) approved the ratification of the Multilateral Agreement on the Implementation of Tax Treaty Related Measures to Prevent Base Erosion and Profit Shifting (MLI). It was approved by the
See MoreNigeria: Tribunal issues decision in a case on dividends paid from tax exempt income
The Tax Appeal Tribunal issued a decision in a case entitled “United Capital Asset Management Ltd and United Capital Trustee Ltd v. Federal Inland Revenue Service” on the application of excess dividend tax in terms of section 19 of the
See MoreRussia: MOF clarification on CFC profits
On 5 November 2019, the Russian Ministry of Finance (MOF) issued the letter No. 03-03-06 / 1/85022 concerning the profits of controlled foreign companies (CFC) in cases where a controlling person has an indirect participation in a CFC through legal
See MoreBulgaria submits proposal to amends the TP documentation threshold
On 12 November 2019, some of policy makers submitted to Parliament a proposal to amend the rules on thresholds for the Transfer Pricing (TP) documentation rules. It is proposed that the obligation to prepare such documents will not apply to persons
See MoreGermany: Federal Parliament approves Annual Tax Act 2019
On 7 November 2019, the German Federal Parliament passed the Annual Tax Act 2019. The German Federal Council is expected to approve the Annual Tax Act on 28 November 2019. The changes shall generally come into effect as of 1 January
See MoreLatvia deposits its Multilateral Convention ratification instrument
On 29 October 2019, OECD confirmed that Latvia deposited its instrument of ratification for the multilateral convention to implement tax treaty related measures to prevent base erosion and profit shifting (BEPS MLI). The MLI is a multilateral tax
See MoreMalta updates notional interest deduction (NID) guidelines
On 7 November 2019, the Maltese Commissioner for Revenue has updated notional interest deduction (NID) guidelines. The guidelines address a new paragraph regarding attribution of the deemed interest income on alternative bases. The following
See MorePeru extends tax incentives for R&D investments until 2022
On 31 October 2019, Peru published an Urgent Decree 010-2019 in the official gazette modifying Legislative Decree No. 30309. The Decree promotes scientific research, technological development and technological innovation. The tax benefits are
See MoreBulgaria: Council of Ministers approves the Budget for 2020
On 31 October 2019, the Council of Ministers approved the draft budget for 2020 and submitted it to the National Assembly for final approval. The draft budget includes the following measures: Procedures to improve the business environment and
See MorePeru extends tax incentives for real estate funds until 2022
On 31 October 2019, Peru published an Urgent Decree 009-2019 in the official gazette modifying Legislative Decree No. 1188. The Decree approves the extension of the validity of tax incentives to promote real estate investment funds until December
See MoreAustria implements the Mandatory Disclosure Rules
On 22 October 2019, the government of Austria officially published the EU-Mandatory Disclosure Act implementing the European Union (EU) Directive on the mandatory disclosure and exchange of cross-border tax arrangements (DAC6). Under DAC6,
See MoreSlovenia publishes amendments to the CITA in the Official Gazette
On 5 November 2019, the Slovenian government published the amendments to the Corporate Income Tax Act (CITA) in the Official Gazette.
See MoreColombia: MinHacienda issues decree on taxation of investment funds and PEs
On October 29, the Colombian Ministry of Finance and Public Credit (MinHacienda) has issued Decree 1973, which clarified measures regarding the taxation of private equity funds and collective investment funds and rules on the attribution of income
See MoreWorld Tax Brief: November 2019
Russia Interest on late payments: On 25 October 2019, the Russian Central Bank reduced the interest rate from 7% to 6.5% with effect from 28 October 2019.See the story in RegfollowerTax base: On 30 September 2019, the Russian
See MoreMexico: Congress approves tax reform package for 2020
On 30 October 2019, Mexico’s Congress has approved the tax reform for 2020 which was presented by President Andrés Manuel López Obrador’s on September 8, 2019. The Reform incorporates fundamentals of the Base Erosion and Profit Shifting
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