Transfer Pricing Brief: October 2019
GreeceCbC reporting requirement: On 17 September 2019, the Greek Public Revenue Authority (AADE) released a Circular 1341 / 09-09-2019 containing amendments regarding the submission process of CbC notifications. Under this new Circular,
See MoreUkraine increases penalties for tax evasion
On 23 September 2019, the Ukrainian President Volodymyr Zelenskyi has signed Law No. 101-IX on amendments to the Criminal Code of Ukraine and the Criminal Procedure Code of Ukraine, as adopted by the Parliament on 18 September 2019. The Law
See MoreSouth Africa: SARS publishes draft IN18 on rebate and deduction of foreign taxes on income
On 12 September 2019, the South African Revenue Service (SARS) published draft Interpretation Note 18 (Issue 4) (IN18) regarding the rebate and deduction of foreign taxes on income for public comment. This interpretation note describes the scope,
See MoreDenmark deposits ratification instrument for MLI
On 30 September 2019, Denmark deposited its ratification instrument for the Multilateral Convention to Implement Tax Treaty Related Measures (MLI) to Prevent Base Erosion and Profit Shifting. The MLI is designed to allow countries to swiftly add to
See MoreIndia: MLI enters into force
On 1 October 2019, the Multilateral Convention to Implement Tax Treaty Related Measures to Prevent Base Erosion and Profit Shifting (MLI) entered into force with respect of India. On 25 June 2019, India has deposited its instrument of ratification
See MorePoland: Council of Ministers adopts draft budget law for 2020
On 24 September 2019, the Poland Council of Ministers adopted the draft budget law for 2020. For the first time since 1989, there will be no deficit in the budget. The 2020 Budget changes the following tax measures on personal income tax; Tax
See MoreIceland: Government announces fiscal budget proposal for 2020
On 6 September 2019, Mr. Bjarni Benediktsson, the honorable Minister of Finance and Economic Affairs of Iceland introduced the fiscal budget proposal for 2020 that would be presented before Parliament on Tuesday 10 September 2019. Among the salient
See MoreCosta Rica publishes a resolution on the list of non-cooperative jurisdictions for tax purposes
On 25 September 2019, the Costa Rican Ministry of Finance published a resolution No. DGT-R-55-2019 on the list of non-cooperative jurisdictions for tax purposes. The list includes Bosnia and Herzegovina, Cuba, Eritrea, French Polynesia, Guadeloupe,
See MoreIndia: ITAT ruled that the Liaison Office of Hitachi constitutes a PE
On 17 September 2019, the Delhi Bench of the Income Tax Appellate Tribunal (ITAT) in the case of: Hitachi High Technologies Singapore Pte Ltd vs. DCIT , held that a Liaison Office (LO) of Hitachi Technologies Singapore Pte Limited constituted a
See MoreLuxembourg: EU General Court upholds EC Commission’s decision in Fiat case
On 24 September 2019, the EU General Court upheld the Commission’s decision that Fiat received unlawful State aid from Luxembourg, and at the same time cancelled the decision which had found the same with respect to Starbucks in the
See MoreGreece: AADE publishes Circular 1341 / 09-09-2019 on CbC notification process
On 17 September 2019, the Greek Public Revenue Authority (AADE) released a Circular 1341 / 09-09-2019 containing amendments to Decision POL. 1184 of 22 November 2017 regarding the submission process of CbC notifications. Under this new Circular,
See MoreBelgium announces compliance for pre-filing requests regarding TP
The Belgian ruling commission has announced that pre-filing requests or ruling requests concerning Transfer Pricing (TP) or the patent income deduction regarding the corporate income tax return that will be filed by the end of September 2020 must
See MoreEgypt: MOF issues draft budget for 2019-2020
On 21 September 2019, Egypt’s Ministry of Finance (MOF) has issued draft budget for 2019-2020 which is scheduled to be discussed during the next parliamentary session. The draft budget includes following tax incentives: The draft budget
See MoreGermany publishes new draft of DAC 6 implementation law
On 26 September 2019, federal government of German issued a draft proposal regarding the implementation of mandatory disclosure rules pursuant to the EU’s Council Directive 2018/822 of 25 May 2018 (commonly referred to as DAC 6) into Germany’s
See MoreNigeria: FIRS issues Income Tax (CRS) Regulations, 2019
Recently, the Federal Inland Revenue Service (FIRS) issued the Income Tax (Common Reporting Standard (CRS)) Regulations, 2019. The effective date of the regulations is 1 July 2019. This follows Nigeria's signing of the Multilateral Convention on
See MoreMalaysia withdraws withholding tax exemptions available to MSC Malaysia status companies
Malaysia Digital Economy Corporation Sdn Bhd (MDEC) has recently announced on its website that the withholding tax (WHT) exemption on certain types of income received by a non-resident company from an approved Multimedia Super Corridor (MSC)
See MoreUkraine submits draft law on amendments to the Tax Code to Parliament
On 30 August 2019, the Ukraine has submitted draft law no. 1210 to the Parliament amending the Tax Code on improving tax administration, removing technical and logical mismatches in the tax legislation. The three main areas of the draft law
See MorePeru: SUNAT publishes report on GAAR
On 17 September 2019, the Peruvian Tax Administration (SUNAT) published Report No. 116-2019-SUNAT / 7T000 of 27 August 2019 on its website, through which SUNAT clarifies the application of General Anti-Avoidance Rule (GAAR). On 19 July 2012,
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