Australia updates guideline for simplified transfer pricing record keeping options
On 11 September 2019, the Australian Taxation Office (ATO) released an updated version of Practical Compliance Guideline (PCG) 2017/2 concerning the eligibility criteria for applying simplified transfer pricing record keeping options for
See MoreItaly: New resolution amends patent box regime
The Italian Revenue Agency published Resolution No, 81/E of 9 September 2019 in the official gazette to amend the patent box regime made by Law Decree No. 34 of 30 April 2019, which entered into force on 1 May 2019. The updates
See MoreIndia: CBDT issues Notification on transfer pricing arm’s length tolerance range
On 13 September 2019, the Central Board of Direct Taxes (CBDT) published Notification No. 64/2019, which sets a tolerance range for the variation between the arm’s length price and the transaction price for the 2019-20 assessment year. The
See MoreCzech Republic: Cabinet approves draft budget for 2020
On 16 September 2019, Government announced that Czech cabinet approved the draft budget proposal for 2020. This draft budget was prepared by the Ministry of Finance. It focuses mainly on pensions, wages, parental allowance and government spending
See MoreFrance: Court issues an explanatory note and six decisions on tax evasion
The Criminal Division of the Court of Cassation published an explanatory note and delivered six important decisions (n. 1174, no. 1175, no. 1176, no. 1177, no. 1178 and no. 1179) subsequently. This explanatory note helps to explain the exact place
See MoreDominican Republic: Public Finance Ministry presents annual budget policy 2020
On 10 September 2019, the Ministry of Public Finance presented an annual budgetary proposal for the year 2020 and sent it to the Executive Branch to take it into account for the annual budget. It covers financial activities, excise duty on alcohol
See MoreArgentina: AFIP issues new General Resolution 4579/2019 for surcharge on import of goods
On 17 September 2019, the General Resolution 4579 was published in the Official Gazette, amending General Resolution 2281 in order to eliminate the different perception income tax rate on the definitive importation targets for consumption. This
See MoreDenmark: Draft bill on international taxation submits for public comments
On 12 September 2019, the Ministry of Taxes published a major bill on international taxation. The bill will be subjected to a public hearing and subsequently presented to the Danish Parliament. Interested parties can submit their comments by 10
See MoreVietnam clarifies the limitation of the deductibility of loan interest expense for TP purposes
On 11 September 2019, the Department of Taxation of Ha Noi City issued Official Letter No. 71443/CT-TTHT providing clarification on the determination of loan interest costs. Under article 8 (3) of Decree No 20/2017 / ND-CP, the total loan
See MoreCanada deposits ratification instrument for MLI
On 29 August 2019, Canada deposited its ratification instrument for the Multilateral Convention to Implement Tax Treaty Related Measures (MLI) to Prevent Base Erosion and Profit Shifting. The MLI would enter into force on the first day of the
See MoreMexico: Tax reform proposal in economic package 2020
On 8 September 2019, Mexican president Andrés Manuel López Obrador’s presented Economic Package for the fiscal year 2020 to Congress. The economic package proposed following tax reform measures: Transparent Entities International
See MoreGermany presents Budget for 2020
On 10 September 2019, the Finance Minister presented the Government's draft Budget for 2020 to the lower house of parliament (the Bundestag). The draft budget includes following measures: Currently, the solidarity tax is a 5.5% surtax on
See MoreColombia: Reminder on tax amnesty deadline
It’s a reminder for the Colombian taxpayers wishing to take part in ongoing tax amnesties. The Colombian 2019 tax reform establishes a tax amnesty to “normalize” (i) unreported assets; or (ii) nonexistent liabilities that were included on a
See MoreSouth Africa: SARS publishes comprehensive guide to dividends tax
The South African Revenue Service (SARS) published a comprehensive guide to dividends tax on 12 September 2019. The objective of this guide is to help users in gaining a more in-depth understanding of dividends tax. This guide is not an ‘official
See MoreUK amends hybrid capital instruments rules
The ‘hybrid capital instruments’ rules are relied upon since 1 January 2019 by many banks and insurers to give corporation tax relief for the coupon payments on regulatory capital securities. These rules have recently been amended by the
See MoreSaudi Arabia: GAZT requests for TP documentation
Recently, the General Authority of Zakat and Tax (GAZT) of Saudi Arabia have requested the taxpayers to submit specific transfer pricing (TP) documentation (master file and local file) in relation to the fiscal year ending 31 December
See MoreRomania introduces mandatory online submission for CbC Reporting
On 19 August 2019, Romania has published Order No. 2.273, amending the rules on submission of Country-by-Country (CbC) reports and notifications, effective from 26 August 2019. Now both CbC reports and notifications must be submitted through
See MorePanama updates penalty provision to tackle tax evasion
Cabinet Council of Panama has approved a proposed legislative amendment to strengthen the penalty provision for repeated tax evasion. The proposal follows the enactment of law 70 of 31 January 2019, which criminalizes tax evasion for the first
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