Canada: BEPS multilateral instrument (MLI) enters into force
On 1 December 2019, the Multilateral Convention to Implement Tax Treaty Related Measures to Prevent Base Erosion and Profit Shifting (MLI) entered into force for Canada. On 29 August 2019, Canada deposited its ratification instrument for
See MoreHigh Court rules that the Danish loss-making company could not deduct royalties paid to its Swiss parent
On 28 October 2019, the Eastern High Court of Denmark published a case (Denmark vs Adecco; Case No SKM2019.537.OLR of 4 July 2019) decision and agreed with the tax authority that a Danish loss-making company could not deduct royalties paid to its
See MoreFinland: Government submits draft proposal on mandatory disclosure rules to parliament
On 31 October 2019, the Finnish Government has submitted a legislative proposal implementing the EU directive on the mandatory disclosure and exchange of cross-border tax arrangements, also known as DAC 6, to the Parliament. Under DAC6, taxpayers
See MoreUkraine: Parliament adopts law on state budget for 2020
On 14 November 2019, the Ukrainian Parliament has adopted Draft Law on the State Budget of Ukraine for 2020. There is no increase in the general rate of corporate or individual tax. Expenditures are estimated at UAH 1.18 trillion, including general
See MoreBulgaria: Parliament approves the Budget for 2020
On 5 December 2019, Bulgaria's parliament has approved the 2020 budget Act for 2020. The budget envisages increased spending for pensions, salaries for teachers, and public sector salaries, as well as more funds for healthcare. The 2020 budget
See MoreUkraine: SFS issues guidance letter on taxation of freight forwarding services
On 20 November 2019, the State Financial Service (SFS) of Ukraine has issued guidance letter no. 1237/6/99-00-07-02-02-15/IPK regarding taxation of freight forwarding services. The letter clarified that the amount of freight paid by a resident
See MoreColombia introduces new tax incentives for special economic zones (SEZs)
On November 24, the Colombian Ministry of Finance and Public Credit (MinHacienda) issued Decree No. 2112 of 2019, by which Colombia introduces new tax incentives for commercial companies established in special economic zones (SEZs). The Decree
See MoreCroatia: Parliament approves tax reforms
On 29 November 2019, the Croatian Parliament approved the Tax Reform. On 23 November 2019, the fourth tax reform round sent to Parliament for second reading. It will come into force from 1st January 2020. As for income tax, the non-taxable
See MoreLithuania proposes amendments to the CITL
On 31 October 2019, the parliament proposed a Bill (No. XIIIP-4116) to amend the Corporate Income Tax Law (CITL). The proposal includes the following measures: The taxable profit of a Lithuanian entities and a Lithuanian permanent
See MoreDenmark publishes the Bill no. L 48 on international taxation
On 6 November 2019, the Danish Minister of Taxation published Bill no. L 48 on international taxation. The bill updated the existing PE (permanent establishment) rules, CFC rules and strengthen the Transfer pricing (TP) rules. PE rules: The
See MoreEcuador presents new tax reform Bill
On 21 November 2019, the Ecuadorian National Assembly presented a new draft of the Tax Reform Bill on "Tax Simplicity and Progressiveness" following the rejection of the previous draft law on economic growth reform submitted to Congress on 18
See MoreOman signs MLI to implement tax treaty related BEPS measures
On 26 November 2019, Oman signed the Multilateral Convention to Implement Tax Treaty Related Measures to Prevent Base Erosion and Profit Shifting (MLI). Oman also signed the Multilateral Convention on Mutual Administrative Assistance in Tax
See MoreKenya signs BEPS MLI on multinational group taxation
On 26 November 2019, Kenya signed the Multilateral Convention to Implement Tax Treaty Related Measures to Prevent Base Erosion and Profit Shifting (MLI). The provisional list of reservations and notifications to the MLI (i.e. its MLI position)
See MoreEU tax dispute resolution directive enters into force in Latvian domestic law
On 22 October 2019, the Law of 17 October 2019 on amendments to the Law on Taxes and Duties has been published in the Latvian official gazette, which provides for the implementation of Council Directive (EU) 2017/1852 of 10 October 2017. The
See MoreBulgaria approves changes to the TP documentation threshold
On 21 November 2019, the Bulgarian parliament approved amendments to the thresholds for mandatory preparation of a local transfer pricing file. According to the amendments, the obligation to prepare such documents from 1 January 2020 will not
See MoreUS: IRS issues a notice requesting comments on CbC form
On 6 November 2019, the US Internal Revenue Service (IRS) published a notice requesting comments concerning IRS Form 8975 regarding CbC report. The Internal Revenue Service, as part of its continuing effort to reduce paperwork and respondent
See MoreSweden: Tax Agency issues guidance on DAC6 reporting
On 25 October 2019, the Swedish Tax Agency issued a guidance on the implementation of an EU Council Directive on the mandatory automatic exchange of information in relation to reportable cross-border arrangements (DAC6). The guidance includes the
See MoreFrance: National Assembly adopts first reading of Finance Bill for 2020
On 19 November 2019, the National Assembly adopted the first reading of the PLF (Finance Bill) for the year 2020. The Minister of Economy and Finance and the Minister of Action and Public Accounts presented the draft budget law for 2020 on 27
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