Denmark: Tax Agency allows for the opportunity to re-open certain transfer pricing cases
On 12 July 2019 the Danish Tax Agency issued a new decree (SKM2019.374.SKTtST) regarding transfer pricing documentation in response to the Supreme Court’s decision in the Microsoft case. The decree allows some taxpayers to reopen Denmark transfer
See MoreUS: IRS withdraws “Altera Memo” directive on cost-sharing arrangements
On 5 August 2019, the U.S. IRS published a memorandum dated 31 July 2019 on the formal withdraw of Directive LB&I-04-0118-005. Directive LB&I-04-0118-005 was issued on 12 January 2018 and provided instructions for examiners on transfer
See MoreLithuania further changes TP documentation rules
On 12 August 2019, the tax authorities released the new transfer pricing (TP) rules, which will apply from 2019, in addition to the previously announced new TP rules. The tax authorities also include the following TP measures: Abolishing the
See MoreRussia updates the CFC notification form
On 1 August 2019, the Federal Tax Service (FTS) has approved the amended CFC and the filing procedure in electronic form with an order of 5 July 2019 No. MMV-7-13 / 338. This regulation extends the list of information on foreign organizations
See MorePhilippines: House Committee approves bill on corporate income tax reform
The House Committee on Ways and Means has approved the administration’s second tax reform package (Corporate Income Tax and Incentives Reform Act (CITIRA)) on 14 August 2019, which aims to reduce corporate income taxes (CIT) and rationalize
See MoreDominican Republic: Government introduces new simplified tax regime for small taxpayers
The Dominican Republic published Presidential Decree No. 265-19 of 1 August 2019, which introduces a new simplified tax regime (RST) for small entities. This previous simplified tax regime is canceled and RST is applicable for both legal and
See MoreMalta announces deduction rules for patent box regime
On 13 August 2019, the Government of Malta has published Legal Notice 208 of 2019 introducing ‘Patent Box Regime (Deduction) Rules, 2019’ on qualifying intellectual property (IP). The patent box regime grants additional tax deductions on income
See MorePakistan: FBR approves the Finance Act 2019 with certain changes
On 30 July 2019, the Federal Board of Revenue (FBR) has issued a Circular No. 9 of 2019. The Circular contains important changes to the Income Taxation Act 2001 through the Finance Act 2019, which was published in the Official Journal on 30 June
See MoreGhana: Finance Minister presents mid-year budget for 2019
On 29 July 2019, the Finance Minister of Ghana presented the 2019 mid-year budget statement to the parliament. The budget proposed the following measures: Increasing in Communication Service Tax from 6% to 9%;The cancellation of the Luxury
See MoreBulgaria modifies the CFC Rules
The recently published Bulgarian Law amending and supplementing the Tax and Social Security Act includes some modifications and explanations of the rules for Controlled Foreign Companies (CFC), which were introduced with effect from 1 January 2019,
See MoreLuxembourg: Government submits EU Anti-Tax Avoidance Directive to Parliament
On 9 August 2019, Luxembourg Government submits draft law to the Parliament for the execution of the expanded hybrid mismatch rules of the European Union (EU) Anti-tax Avoidance Directive as amended (ATAD2). The draft law aims at broadening the
See MoreBulgaria publishes new mandatory TP documentation requirements
On 13 August 2019, amendments to the Tax and Social Security Procedure Code (TSSPC) were published in the State Gazette. The law introduced the mandatory new transfer pricing (TP) documentation requirements in Bulgaria. Documentation
See MoreArgentina: Tax authorities declares extensions to TP filing deadlines
Tax Authorities has issued General Resolution 4538/2019 of 30 July 2019 and published in the Official Gazette on July 31, 2019. It entered into force from July 31, 2019. This resolution made an extension to timeline to transfer pricing filing
See MoreHungary publishes legislation implementing EU directive on hybrid mismatch rules
On 23 July 2019, Hungary published a legislation through an official gazette that provides for the implementation of exit tax and hybrid mismatch rules of the EU Anti-Tax Avoidance Directive (ATAD). On 12 July 2019, the Hungarian legislator passed
See MoreArgentina amends the compensatory and punitive interest rates
On 18 July 2019, Argentine Federal Secretary of Treasury published Resolution 598/2019 in the official gazette amending Resolution 50/2019 on compensatory and punitive interest rates. According to the Resolution 50/2019, current effective
See MoreNorway deposits ratification instrument for MLI
On 17 July 2019, Norway deposited its instrument of ratification for the multilateral convention to implement tax treaty related measures to prevent base erosion and profit shifting (MLI). The MLI will enter into force on 1 November 2019 for
See MoreLithuania implements EU Directive on mandatory disclosure rules
On 30 July 2019, the President signed the primary legislation implementing the European Union (EU) Directive on the mandatory disclosure and exchange of reportable cross-border tax arrangements (referred to as DAC6 or the Directive) into
See MoreUK: Updated statistics on creative industries tax relief
On 7 August 2019 HMRC published updated statistics on creative industries tax relief. Film tax relief Film tax relief is given at 25% of qualifying production expenditure and is available in the case of British qualifying films that have
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