Denmark: Ministry of Taxation publishes bill to implement EU ATAD with CFC amendments
Recently, the Danish Ministry of Taxation has published a legislation with CFC amendments for the implementation of the measure of the EU Anti-Tax Avoidance Directive (ATAD1) and the Directive as amended (ATAD2). Some of the main changes include:
See MoreEuropean Commission opens in-depth investigation into Netherlands tax rulings
On 10 January 2019 the European Commission announced that it has opened an in-depth investigation into tax rulings granted by the Netherlands to companies in the Nike group. The rulings may have given the companies an unfair competitive advantage
See MoreOECD to launch Corporate Tax Statistics
The OECD announced on 11 January 2019 that a new report and dataset entitled Corporate Tax Statistics is to be published containing internationally comparable statistics and analysis relevant to the debate on tax policy. These statistics that will
See MoreUK: HMRC launches Profit Diversion Compliance Facility
On 10 January 2019 HMRC launched the Profit Diversion Compliance Facility targeting multinational companies using arrangements that may result in a liability to the diverted profits tax (DPT). These arrangements generally involve the reduction of
See MoreRussia publishes list of foreign states for automatic exchange of CbC reports
On 25 December 2018, The Federal Tax Service of Russia published a new list of foreign states (territories), with which Russia will automatically exchange Country-by-Country (CbC) reports. Now the list includes 53 foreign countries and 4
See MoreColombia: Tax authority publishes decree regarding tax return and TP documentation deadline
On 27 December 2018, the Colombian Tax Administration (DIAN) has published Decree No.2442 specifying the deadlines for filing and payment of the tax return (declaration) for 2019 and the deadline for transfer pricing documentation, including
See MoreFrance: Parliament adopts Finance Bill for 2019
On 20 December 2018, the French Parliament approved the Finance Bill for 2019. Tax measures taken under the Finance Bill 2019: The finance bill approves interest deductibility limitation rules in effort to comply with the European Union (EU)
See MoreKorea Rep. enacts tax reform bill for 2019
On 24 December 2018, Korea enacted the 2019 tax reform bill after it was passed by Korea’s National Assembly on 8 December 2018. The 2019 Tax Reform also includes provisions in line with the OECD BEPS Action Plan 7 among others. The 2019 Tax
See MoreItaly approves Budget for 2019
On 29 December 2018, the Italian Parliament approved the 2019 Budget Law no. 145 of 2018 published on the Official Gazette of 31 December 2018. The Budget contains a number of measures related to tax incentives, including changes to the research
See MoreDenmark: Ministry of Taxation publishes bill to implement EU ATAD
On 28 December 2018, the Danish Ministry of Taxation has published a new legislation (Law No 1726) for the implementation of the measure of the EU Anti-Tax Avoidance Directive (ATAD1) and the Directive as amended (ATAD2). The measures
See MoreUS: IRS publishes proposed regulations on certain hybrid arrangements
On 20 December 2018, IRS issued proposed regulations implementing sections 245A(e) and 267A that were added with the enactment of the Tax Cuts and Jobs Act (TCJA). The proposed Regulations concern sections 245A (e) and 267A relating to hybrid
See MoreIreland: President Signs Finance Act 2018
Ireland has published the Finance Act 2018 (Act 30 of 2018), which was approved by parliament and signed into law by the president on 19 December 2018. The Act mainly provides for the implementation of measures announced as part of the 2019 Budget.
See MoreLithuania gazettes new Transfer Pricing rules for 2019
On 31 December 2018, the Lithuanian Official Gazette published an order for the transfer pricing (TP) rules. The new requirements generally reflect measures implementing recommendations under the OECD’s base erosion and profit shifting (BEPS)
See MoreItaly releases ATAD decree in line with EU Anti-Tax Avoidance Directive
On 28 December 2018, the Italian Government published, in the Official Gazette, the Legislative Decree (Decree) transposing the European Union (EU) Anti-Tax Avoidance Directive (ATAD) in the Italian legislation. The Government had previously
See MoreUruguay updates CbC Reporting requirements
On 4 January 2019, Uruguay's Directorate General of Taxation (DGI) has issued Resolution No. 94/2019 regarding submission of Country-by-Country (CbC) reports and notifications. Uruguay's CbC reporting requirements apply fiscal years beginning on 1
See MoreEstonia implements EU ATAD measures
On 28 December 2018, Estonia published the Income Tax Amendment Act in the Official Gazette, apply from 1 January 2019. The key measures of the Act provide the implementation of the EU Anti-Tax Avoidance Directive (ATAD) as urged by the European
See MoreAlgeria publishes finance bill 2019
On 30 December 2018, Algeria's Finance Bill 2019 was published in Official Gazette No. 79 and this Bill came into force as of 1 January 2019. The key measures introduced by the Finance Bill are following -The bill clarifies provisions regarding
See MoreTransfer Pricing Brief: January 2019
Costa Rica Interest limitation rule: On 4 December 2018, Costa Rica passed a tax reform bill which includes several tax reform measures. Under the law, an interest limitation rule applies which interest expenses that exceed 20% of the
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