Russia: MOF clarification on CFC profits
On 5 November 2019, the Russian Ministry of Finance (MOF) issued the letter No. 03-03-06 / 1/85022 concerning the profits of controlled foreign companies (CFC) in cases where a controlling person has an indirect participation in a CFC through legal
See MoreBulgaria submits proposal to amends the TP documentation threshold
On 12 November 2019, some of policy makers submitted to Parliament a proposal to amend the rules on thresholds for the Transfer Pricing (TP) documentation rules. It is proposed that the obligation to prepare such documents will not apply to persons
See MoreGermany: Federal Parliament approves Annual Tax Act 2019
On 7 November 2019, the German Federal Parliament passed the Annual Tax Act 2019. The German Federal Council is expected to approve the Annual Tax Act on 28 November 2019. The changes shall generally come into effect as of 1 January
See MoreLatvia deposits its Multilateral Convention ratification instrument
On 29 October 2019, OECD confirmed that Latvia deposited its instrument of ratification for the multilateral convention to implement tax treaty related measures to prevent base erosion and profit shifting (BEPS MLI). The MLI is a multilateral tax
See MoreMalta updates notional interest deduction (NID) guidelines
On 7 November 2019, the Maltese Commissioner for Revenue has updated notional interest deduction (NID) guidelines. The guidelines address a new paragraph regarding attribution of the deemed interest income on alternative bases. The following
See MorePeru extends tax incentives for R&D investments until 2022
On 31 October 2019, Peru published an Urgent Decree 010-2019 in the official gazette modifying Legislative Decree No. 30309. The Decree promotes scientific research, technological development and technological innovation. The tax benefits are
See MoreBulgaria: Council of Ministers approves the Budget for 2020
On 31 October 2019, the Council of Ministers approved the draft budget for 2020 and submitted it to the National Assembly for final approval. The draft budget includes the following measures: Procedures to improve the business environment and
See MorePeru extends tax incentives for real estate funds until 2022
On 31 October 2019, Peru published an Urgent Decree 009-2019 in the official gazette modifying Legislative Decree No. 1188. The Decree approves the extension of the validity of tax incentives to promote real estate investment funds until December
See MoreAustria implements the Mandatory Disclosure Rules
On 22 October 2019, the government of Austria officially published the EU-Mandatory Disclosure Act implementing the European Union (EU) Directive on the mandatory disclosure and exchange of cross-border tax arrangements (DAC6). Under DAC6,
See MoreSlovenia publishes amendments to the CITA in the Official Gazette
On 5 November 2019, the Slovenian government published the amendments to the Corporate Income Tax Act (CITA) in the Official Gazette.
See MoreColombia: MinHacienda issues decree on taxation of investment funds and PEs
On October 29, the Colombian Ministry of Finance and Public Credit (MinHacienda) has issued Decree 1973, which clarified measures regarding the taxation of private equity funds and collective investment funds and rules on the attribution of income
See MoreWorld Tax Brief: November 2019
Russia Interest on late payments: On 25 October 2019, the Russian Central Bank reduced the interest rate from 7% to 6.5% with effect from 28 October 2019.See the story in RegfollowerTax base: On 30 September 2019, the Russian
See MoreMexico: Congress approves tax reform package for 2020
On 30 October 2019, Mexico’s Congress has approved the tax reform for 2020 which was presented by President Andrés Manuel López Obrador’s on September 8, 2019. The Reform incorporates fundamentals of the Base Erosion and Profit Shifting
See MoreIreland: Finance Minister publishes draft law regarding mandatory disclosure rules
On 17 October 2019, the Finance Minister published draft legislation as part of Finance Bill 2019 for the implementation of European Union (EU) Directive 2018/822 regarding mandatory disclosure and exchange of cross-border tax arrangements (DAC6)
See MoreChile: Finance Ministry and Finance Committee modifies tax reform packages
On 5 November 2019, the Finance Ministry and Senate Finance Committee made an announcement that they have come up with an agreement regarding important changes on tax reform package, which was approved by the Chamber of Deputies on 23 August 2019.
See MoreTransfer Pricing Brief: November 2019
SloveniaMain corporate income tax rate: Slovenia increased the corporate income tax rate from 19% to 20% with minimum tax rate 7% under the amendments of corporate income tax act. Special rules for hybrid instruments or entities: Slovenian
See MoreSpain launches a public consultation on DAC6 reporting requirements
On 21 October 2019, the Spanish Ministry of Finance has launched a public consultation on the draft regulation approving the model forms to be used in the context of the implementation of Council Directive (EU) 2018/822 of 25 May 2018 (DAC6) on
See MoreVietnam clarifies the tax implications of interest income
On 24 October 2019, the Tax Authority issued an official letter (No. 80503 / CT-TTHT) explaining the tax implications of interest income on term loans. The letter clarifies that loan interest earned in Vietnam is subject to withholding tax. The
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