Taiwan: NTBCA issues notice on withholding tax for profit-seeking enterprises
On 9 August 2019, Taiwan's National Taxation Bureau of the Central Area (NTBCA) has issued a notice clarifying that profit-seeking enterprises should file withholding tax during prescribed period. The authority indicates that profit-seeking
See MoreBelgium: CbC report corrections guidelines
On 30 July 2019, the Federal Public Service Finance of Belgium issued a notice on its transfer pricing - BEPS 13 guidance page that the MyMinfin Portal is now available for the submission of Country-by-Country (CbC) report
See MoreBulgaria approves CbC Exchange Agreements with U.S.
On 10 July 2019, Bulgaria's Council of Ministers approved two agreements with the United States allowing for the automatic exchange of country-by-country reports. The CbC report is one element of the three-tiered standardized approach to transfer
See MorePeru: SUNAT issues resolutions on GAAR
On 31 July 2019, the Peruvian Tax Administration (SUNAT) published two resolutions (152-2019/SUNAT and 153-2019/SUNAT) regarding general anti-avoidance rule (GAAR) in the Official Journal. The two resolutions are summarized below: Resolution
See MoreEgypt amends interest rate for late payment of tax
On 4 August 2019, the Ministry of Finance issued Decision No 484 of 2019 in the Official Journal. The decision entered into force on 5 August 2019. The decision sets interest rates on unpaid taxes amending the Implementing Regulation to the Income
See MoreRussia reduces the interest rate from July 2019
On 26 July 2019, the Russian Central Bank announced the decision to reduce the key rate from 7.50% to 7.25% with effect from 29 July 2019. For tax purposes, the key rate is important in relation to the safe harbor rates for interest income
See MoreSaudi Arabia signs MCAA for the exchange of CbCR
On 6 August 2019, Saudi Arabian Government signed the Multilateral Competent Authority Agreement (MCAA) for the exchange of Country-by-Country reports (CbCR). According to OECD, total signatories to the agreement CbC MCAA are now 80.
See MoreBulgaria approves new mandatory TP documentation requirements
On 31 July 2019, the National Assembly approved at second (final) reading amendments to the Tax and Social Security Procedure Code (TSSPC), which introduced the new transfer pricing (TP) documentation requirements. New rules for TP
See MoreHong Kong issues practice note in the methodology for attributing profits to PEs
On 19 July 2019, the Inland Revenue Department (IRD) released Departmental Interpretation and Practice Note 60 (DIPN 60) which explains the concept of permanent establishment (PE) and the methodology for attributing profits to Hong Kong
See MoreWorld Tax Brief: August 2019
HungaryIncentive on small business: On 12 July 2019, the Hungarian Lawmakers approved the 2020 budget. The budget reduced the rate of small enterprise tax (KIVA) from 13% to 12% and cancel the simplified entrepreneurial tax (EVA). Payment
See MoreChina: introduces incentives for tourism industry
On 3 August 2019, China's Ministry of Finance and State Taxation Administration have jointly published Notice No. 63 of 2 August 2019 providing incentives to boost up tourism industry in the Guangdong Hengqin New Area. The primary incentive for
See MoreUganda: Parliament passes Income Tax (Amendment) Act 2019
On 30 June 2019, Ugandan Parliament has passed Income Tax Amendment Act 2019. The act contains a number of measures including definition of beneficial owner to reduce the threshold required for exemption; to provide for withholding tax by a seller
See MoreFrance: President signs new Law of digital services tax
The new Law No. 2019-759 has been published on July 25, 2019, in the Official Gazette, which introduces Digital Services Tax (DST). It was signed by the French President, Emmanuel Macron, on July 24, 2019. This new Law also modifies the downward
See MoreTanzania: Government publishes Finance Act, 2019
The Tanzanian Government has published the Finance Act, 2019 in the Official Gazette on 30 June 2019 and it became effective from 1 July 2019. On 13 June 2019, Philip Mpango, the Finance Minister, presented the Budget for financial year (FY)
See MoreColombia: DIAN issues ruling on tax treatment of stock dividends
Recently, the Colombian National Tax Authority (DIAN) published Ruling 014495 of 6 June 2019, which sets out tax of profits in shares or stock dividend. The ruling includes the following points: Article 30 of the Tax Code (TC) provide the
See MoreCanada: Finance Department publishes draft Budget proposals for public comments
On 30 July 2019, the Finance Department published draft Budget proposals inviting comments to implement some of the remaining measures from the 2019 budget. The deadline for public comments is 7 October
See MoreEcuador introduces TP risk model
On 1 August 2019, the Inter-America Center of Tax Administration (CIAT) publishes a document on Ecuador Transfer Pricing (TP) Risk Model in its official website. The SRI of Ecuador, with the coordinated support of CIAT, the United Nations (UN), the
See MoreTransfer Pricing Brief: August 2019
MalaysiaRestriction on interest deduction: On 5 July 2019, the Inland Revenue Board of Malaysia has published new guidance on restrictions to the deductibility of interest expenses. Under the rules the maximum amount of deductible interest is
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