Bulgaria includes new CFC rule and updates interest limitation rule
On 27 November 2018, Bulgaria published a Bill on amendment and supplement to the Corporate Income Tax Act in the Official Gazette. The Bill includes a new interest limitation and controlled foreign company (CFC) rules in accordance with the EU
See MoreBelgium issues draft TP guidelines for public comments
The tax authority of Belgium has published a draft Circular on the 2017 update to the Organisation for Economic Co-operation and Development (OECD) Transfer Pricing (TP) Guidelines. On 9 November 2018, the draft Circular was published by the Belgian
See MoreTransfer Pricing Brief: December 2018
Finland Control: On 1 November 2018, the Ministry of Finance submitted a bill to Parliament proposing changes to the CFC rules. Under the proposed rules, the control threshold setting the CFC status would be reduced from 50% to 25%, and the
See MoreMexico: SAT publishes the Miscellaneous Fiscal Resolution for 2018
On 30 November 2018, the Tax Administration Service (SAT) published in its portal the "Fourth of Modifications to the Miscellaneous Fiscal Resolution for 2018" and its annexes. Modifications to the value of operations with related parties within the
See MoreMexico publishes the Fourth Resolution of Modifications to the Miscellaneous Fiscal Resolution for 2018
On 30 November 2018, the Fourth Resolution of Modifications to the Miscellaneous Fiscal Resolution for 2018 and Annexes 1, 1-A, 3, 7, 11 and 23 were published in the Official Gazette. Among others the modification added as a criterion in terms of
See MoreQatar signs MLI to implement tax treaty regarding BEPS measures
The OECD announced on December 4, 2018, that Qatar has signed the Multilateral Convention to Implement Tax Treaty Related Measures to Prevent Base Erosion and Profit Shifting (BEPS). Qatar is the 85th jurisdiction to join the treaty. This treaty
See MoreBrazil: Revenue Authority publishes new Normative Instruction regarding MAP
On November 29, 2018, the Revenue Authority published Normative Instruction No. 1846 of 28 November 2018 that covers the rules for submitting a Mutual Agreement Procedure (MAP) request, the approval of a request, and the termination process. It
See MoreVietnam: NFSC proposes to cut the corporate income tax on SMEs
The National Financial Supervisory Committee (NFSC) has proposed cuts to corporate income tax for small-and-medium sized enterprises to promote their development. This was a highlighted in the January-September fiscal and budget report by the
See MoreBrazil: Tax tribunal publishes a decision on costs included for resale price method
On November 20, 2018, the Administrative Tribunal for Federal Tax Cases (CARF) has published Decision 1402003338 of 14 August 2018. This decision states that all the expenses regarding freight, insurance, and customs need to include when allowed by
See MoreVietnam considering amendments to rules that limit related-party interest deductions
According to recent reports, the Vietnam Ministry of Finance is considering proposed amendments to the country's interest expense deduction restriction. The Decree No. 20/2017/ND-CP, enacted 24 February 2017 (Decree 20), limits deductions
See MoreChina: CbC reporting requirement for certain outbound MNCs alleviated
China has initiated country-by-country (CbC) reporting and exchange relationships with 44 countries. China expands current exchange relationship with the UK, France, and Germany. For Chinese outbound multinational companies (MNCs), the expanded CbC
See MoreAustralia: ATO extends deadline to file CbC reports
Significant Global Entities (SGE) that have a Country-by-Country (CbC) reporting obligation for the year ended 31 December 2017 will be aware that the Local file, Master file, and CbC report are due to be lodged by 31 December 2018. However, due
See MorePoland: President signed an act including amendment of TP measures effective in 2019
On 14 November 2018, President of Poland signed an act including amendment of transfer pricing measures effective in 2019. The new laws repeal the Article 9a of the CIT Act regarding transfer pricing, which is being replaced by Chapter 1a,
See MoreUS: IRS announces priority guidance plans addressing many new international tax issues
On 8 November 2018, the US Treasury and IRS published its 2018–2019 Priority Guidance Plan, detailing tax guidance the government intends to focus its effort on in the coming months. The Guidance Priority List focuses resources on guidance items
See MoreThailand enacts Transfer pricing law
On 21 November 2018, Thailand's new transfer pricing law was enacted and published in the Official Gazette and will be effective from 1 January 2019, which was approved by the National Legislative Assembly in 27 September 2018. Tax assessment
See MoreDenmark: Court imposes fines for not providing timely submission of TP documents
On 19 November 2018, the Danish tax authority published an overview of a decision by the Copenhagen Court on whether a company acted in a grossly negligent act for failing to submit the timely submission of transfer pricing (TP) documents and should
See MoreIMF report comments on Spain’s fiscal position
On 19 November 2018, the International Monetary Fund (IMF) issued a report following consultations with Spain under Article IV of the IMF articles of agreement. In Spain the real GDP growth is expected to decrease to 2.5% percent in 2018 and to
See MoreBrazil: Government publishes new Decree 9,580
The Government published Decree 9,580 of November 22, 2018 in the Official Gazette on November 23, 2018, which revises the previous Decree No. 3000 of 1999. The new decree compiles provisions related to personal income tax, corporate income tax and
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