Colombia updates late payment interest rate for July 2018

11 July, 2018

According to Administrative Regulation 0820 of 2018, the effective monthly interest rate for late payment of taxes has been set at 28.05% and valid from 1 to 31 July

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Hungary presents new tax package for 2019

11 July, 2018

The government of Hungary presented a new tax package on 19 June 2018 for corporate and business tax. The changes of taxes are as follows: The deduction allowance for investment in start-ups will be capped at HUF 20 million; A deduction for

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Peru: Tax administration clarifies the exchange rate applicable to capital gains arising from the transfer of shares

10 July, 2018

On 3 November 2017, the tax Administration in Peru issued report no. 039-2017-SUNAT/7T0000, clarifying the exchange rate applicable to capital gains arising from the transfer of shares. The report refers to a transaction as part of which a

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India: CBDT publishes guidance on appropriate use of CbC reports

10 July, 2018

On 27 June 2018, the central board of direct taxes (CBDT) released Instruction No. 02/2018 to provide guidance on the appropriate use of CbC (Country-by-Country reports) reports. In 2015, the Organization for Economic Co-operation and Development

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Brazil: Government sanctioned guidance regarding new tax incentives for automotive sector

10 July, 2018

On 5th July 2018 government sanctioned guidance (Provisional Measure 843/18 (PM 843)) that initiates a new tax incentive program for the automotive sector. According to the program the following main tax incentives for a five-year period, which may

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Pakistan: FBR extends tax amnesty scheme period to 31 July 2018

10 July, 2018

On 7 July 2018, the Federal Board of Revenue (FBR) approved an extension in tax amnesty scheme till 31 July 2018. Previously an ordinance was sent to the president of Pakistan for approval of the extension. The deadline for filing amnesty

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India: CBDT publishes notification for taxation of foreign company held as resident in India as per POEM

09 July, 2018

On 22 June 2018, the Central Board of Direct Taxes (CBDT) has issued a final Notification No. 29/2018, dealing with special transitional provisions for a foreign company said to be a resident in India on account of Place of Effective Management

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Norway: MoF sets a late payment interest rate for July to December 2018

08 July, 2018

The Ministry of Finance (Mof) has published a regulation to set the late interest rate for the second half of 2018 (from 1st July 2018 to 31st December 2018). The interest rate is set at 8.50% from 1st July 2018 to 31st December 2018, which is

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Hong Kong: Legislative council passes the transfer pricing legislation

08 July, 2018

On 4 July 2018, the Legislative Council adopted the new transfer pricing regime ((Amendment) (No. 6) Bill 2017 (the “BEPS Bill”)). During the legislative process, some changes were made to the initial bill. Remarkable changes are the possible

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Turkey: General Communiqué No. 500 has been gazetted

08 July, 2018

The General Communiqué No. 500 has published on July 6, 2018, regarding Tax Procedure Law in the Official Gazette. It was entered into force on the similar day of its publication. According to the temporary article 31 of the Tax Procedure Law (or

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Nigeria: Cabinet approves MCAA on financial account information

07 July, 2018

The Cabinet has approved the Multilateral Competent Authority Agreement (MCAA) On July 4, 2018, regarding the automatic exchange of Financial Account Information. It was signed on August 17, 2017.  It provides exchange of information in accordance

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OECD: Discussion Draft on Transfer Pricing for Financial Transactions

05 July, 2018

On 3 July 2018 the OECD released a discussion draft on financial transactions in relation to BEPS actions 8 to 10 (ensuring that transfer pricing outcomes are in line with value creation). This has been issued as part of the follow-up work on the

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Colombia: New resolution for CbC reporting

05 July, 2018

On 21 June 2018, the Colombian National Tax Authority (DIAN) issued a draft resolution concerning the obligation to notify country-by-country (CbC) reporting responsibilities. Resident taxpayers are required to file informative transfer pricing

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Nigeria: FIRS Issues guidelines for CbC reporting regulations

05 July, 2018

The Federal Inland Revenue Service (FIRS) has published the guidelines of Country by Country (CbC) Reporting Regulations on July 3, 2018. These Guidelines are issued to provide guidance to the general public and in particular, Multinational

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Russia publishes Order on CbC report automatic exchange

03 July, 2018

On 26 June 2018, Russia has approved the Order of the Federal Tax Service of 30 May 2018 No. MMV-7-17 / 359 regarding the States and Territories list with which Russia will automatically exchange Country-by-Country (CbC)

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Transfer Pricing Brief: July 2018

01 July, 2018

Sweden Restriction on interest deduction: On 14 June 2018, the Parliament passed a bill regarding a general provision limiting the deductibility of net interest expense to 30% of earnings before interest, tax, depreciation and amortization

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Thailand: Government submits the draft transfer pricing law to the National Legislative Assembly

01 July, 2018

On 5 June 2018, the Government submitted the draft of law amending the Revenue Code on transfer pricing to the National Legislative Assembly for approval. The draft law clarifies that taxpayers who meet the income threshold must prepare and submit

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India: HC decides on principles for admissibility of transfer pricing appeals

01 July, 2018

On 25 June 2018, the Karnataka High Court (HC) announced the decision in the case of Softbrands India Private Limited v. DCIT (TS-475-HC-2018(KAR)-TP). The ruling sets forth some significant principles relating to admissibility of appeals by HCs

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