World Tax Brief: October 2019
Costa Rica Computation of taxable income: On 25 September 2019, the Costa Rican Ministry of Finance issued a Resolution No DGT-R-55-2019 on the list of non-cooperative jurisdictions for tax purposes. According to the list, all expenses
See MoreHong Kong: IRD revises practice notes on deduction of foreign taxes
In the middle of August 2019, the Hong Kong Inland Revenue Department (IRD) revised Departmental Interpretation and Practice Notes No. 28 regarding Deduction of Foreign Taxes (“DIPN 28”). The updated version replaced the one issued on 19 July
See MoreNigeria: FIRS introduces e-filing for submitting TP returns
On 27 September 2019, Federal Inland Revenue Service (FIRS) described the way of how to submit transfer pricing (TP) returns through the electronic platform, when it is active. Now, the FIRS is get ready to automate the process of filing TP
See MorePeru: SUNAT issues resolution on beneficial ownership of entities
On 25 September 2019, the Peruvian Tax Administration (SUNAT) has issued Resolution No. 185-2019/SUNAT establishing the procedure, deadlines and conditions for submitting the ultimate beneficiary informative return of entities. Effective from 1
See MoreFrance: Government presents draft Finance Bill 2020
On 27 September 2019, Government presents Finance Bill for the year 2020 and confirms the willingness to cut the income tax rate for corporate entities; to introduce the hybrid mismatch rules; to implement the EU ATAD 2 directive into domestic law;
See MoreTransfer Pricing Brief: October 2019
GreeceCbC reporting requirement: On 17 September 2019, the Greek Public Revenue Authority (AADE) released a Circular 1341 / 09-09-2019 containing amendments regarding the submission process of CbC notifications. Under this new Circular,
See MoreUkraine increases penalties for tax evasion
On 23 September 2019, the Ukrainian President Volodymyr Zelenskyi has signed Law No. 101-IX on amendments to the Criminal Code of Ukraine and the Criminal Procedure Code of Ukraine, as adopted by the Parliament on 18 September 2019. The Law
See MoreSouth Africa: SARS publishes draft IN18 on rebate and deduction of foreign taxes on income
On 12 September 2019, the South African Revenue Service (SARS) published draft Interpretation Note 18 (Issue 4) (IN18) regarding the rebate and deduction of foreign taxes on income for public comment. This interpretation note describes the scope,
See MoreDenmark deposits ratification instrument for MLI
On 30 September 2019, Denmark deposited its ratification instrument for the Multilateral Convention to Implement Tax Treaty Related Measures (MLI) to Prevent Base Erosion and Profit Shifting. The MLI is designed to allow countries to swiftly add to
See MoreIndia: MLI enters into force
On 1 October 2019, the Multilateral Convention to Implement Tax Treaty Related Measures to Prevent Base Erosion and Profit Shifting (MLI) entered into force with respect of India. On 25 June 2019, India has deposited its instrument of ratification
See MorePoland: Council of Ministers adopts draft budget law for 2020
On 24 September 2019, the Poland Council of Ministers adopted the draft budget law for 2020. For the first time since 1989, there will be no deficit in the budget. The 2020 Budget changes the following tax measures on personal income tax; Tax
See MoreIceland: Government announces fiscal budget proposal for 2020
On 6 September 2019, Mr. Bjarni Benediktsson, the honorable Minister of Finance and Economic Affairs of Iceland introduced the fiscal budget proposal for 2020 that would be presented before Parliament on Tuesday 10 September 2019. Among the salient
See MoreCosta Rica publishes a resolution on the list of non-cooperative jurisdictions for tax purposes
On 25 September 2019, the Costa Rican Ministry of Finance published a resolution No. DGT-R-55-2019 on the list of non-cooperative jurisdictions for tax purposes. The list includes Bosnia and Herzegovina, Cuba, Eritrea, French Polynesia, Guadeloupe,
See MoreIndia: ITAT ruled that the Liaison Office of Hitachi constitutes a PE
On 17 September 2019, the Delhi Bench of the Income Tax Appellate Tribunal (ITAT) in the case of: Hitachi High Technologies Singapore Pte Ltd vs. DCIT , held that a Liaison Office (LO) of Hitachi Technologies Singapore Pte Limited constituted a
See MoreLuxembourg: EU General Court upholds EC Commission’s decision in Fiat case
On 24 September 2019, the EU General Court upheld the Commission’s decision that Fiat received unlawful State aid from Luxembourg, and at the same time cancelled the decision which had found the same with respect to Starbucks in the
See MoreGreece: AADE publishes Circular 1341 / 09-09-2019 on CbC notification process
On 17 September 2019, the Greek Public Revenue Authority (AADE) released a Circular 1341 / 09-09-2019 containing amendments to Decision POL. 1184 of 22 November 2017 regarding the submission process of CbC notifications. Under this new Circular,
See MoreBelgium announces compliance for pre-filing requests regarding TP
The Belgian ruling commission has announced that pre-filing requests or ruling requests concerning Transfer Pricing (TP) or the patent income deduction regarding the corporate income tax return that will be filed by the end of September 2020 must
See MoreEgypt: MOF issues draft budget for 2019-2020
On 21 September 2019, Egypt’s Ministry of Finance (MOF) has issued draft budget for 2019-2020 which is scheduled to be discussed during the next parliamentary session. The draft budget includes following tax incentives: The draft budget
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