Costa Rica: MOF publishes draft resolution on advance pricing agreements (APA)
On 2 July 2019, the Ministry of Finance released a draft resolution providing rules on advance pricing agreements (APA) under the OECD transfer pricing guidelines. The resolution outlined the application procedures for approval, refusal, renewal
See MoreHungary: Parliament passes budget for 2020
On 12 July 2019, the Hungarian Lawmakers approved the 2020 budget. The budget targets revenue of 21,426.0 billion forints and expenditures of 21,793.0 billion forints, producing a deficit of 367.0 billion forints. Highlighted features of the
See MorePortugal approves amendments to the TP rules
On 19 July 2019, the Portuguese parliament approved Law No. 180/2019, which includes amendments to the country's transfer pricing (TP) rules. The new law changes the following rules: Abolishing the hierarchy in the selection of the transfer
See MoreAustralia issues final PCG and ruling on hybrid mismatch rules
The Australian Taxation Office has issued Practical Compliance Guideline (PCG) 2019/6 and Law Companion Ruling (LCR) 2019/3, related to the concept of structure arrangements in relation to Australia's new hybrid mismatch rules.
See MoreIreland introduces EU Directive on Dispute Resolution
Ireland has issued Statutory Instrument (S.I.) No. 306/2019 of 5 July 2019, that includes regulations for the purpose of giving effect to Council Directive (EU) 2017/1852 of 10 October 2017 on dispute resolution. The Directive
See MoreCosta Rica: Tax authority issues guidance on transfer pricing rules
On 26 June 2019, Costa Rican tax authority published the Resolution N° 41818-H in the Official Gazette that changes Income Tax Law regulation including transfer pricing obligations. The new Regulation defines persons as related persons who are
See MoreMalta introduces EU Directive on Dispute Resolution
On 12 July 2019, Malta has published regulations in the Official Gazette implementing Directive of European Union Council Directive (EU) 2017/1852 of 10 October 2017 on tax dispute resolution mechanisms into domestic law. The regulations came
See MoreHungary: Parliament approves exit tax and hybrid mismatch rule in line with ATAD
On 12 July 2019, the Hungarian legislator passed an anti-tax avoidance rule for the implementation exit tax and hybrid mismatch rules in line with the EU Anti-Tax Avoidance Directive (ATAD). The exit tax rules would apply from 1 January 2020
See MoreLuxembourg: Tax administration updates its CbC reporting guidance page
On 16 July 1019, the Luxembourg tax administration released its CbC reporting guidance page with new updates, including a new user manual for the MyGuichet e-filing system for submitting CbC reports and a new XSD schema (XML). Under the new manual
See MoreAustralia introduces a bill to amend thin capitalization rules
On 4 July 2019, the Treasury Laws Amendment (Making Sure Multinationals Pay Their Fair Share of Tax in Australia and Other Measures) Bill 2019 was introduced in the Australian House of Representatives. The purpose of the Treasury Laws
See MoreIndia: The new Finance Act modifies the Transfer pricing law
On 5 July 2019, the Minister of Finance presented the Finance (No.2) Act for the financial year 2019-20. The act changes the following transfer pricing rules: Documentations requirements: Under the new amendments, constituent entity of an
See MoreIreland introduces new Guidance on CFC rules
On 22 July 2019, Ireland has published a new Tax and Duty Manual, Part 35b-01-01 in respect of the Controlled Foreign Company (CFC) rules, that were introduced by Finance Act 2018 and take effect from 1 January 2019. The manual provides an
See MoreDenmark publishes a notice regarding transfer pricing documentation
On 12 July 2019, the Danish Tax Authority has published a notice (SKM2019.374.SKTST) which establishes a new practice for the importance of whether a transfer pricing documentation in its entirety is available at the time of tax return. The
See MoreArgentina: AFIP updates resolution on advance payment of tax
On 12 July 2019, the Federal Administration of Public Revenues (AFIP) of Argentina has published General Resolution No. 4522/2019 amending several provisions of General Resolution 4034 which was issued in 2017. The resolution modifies the
See MoreIndonesia publishes a regulation with tax incentives for investments in certain sectors
On 26 June 2019, the Indonesian government issued a Government Regulation (PP) No. 45 of 2019, which amended Regulation No. 94 of 2010 (GR-94) on the calculation of taxable income and the repayment of income taxes in the current year to stimulate
See MoreUK: Summary of responses to consultation on the restriction on offset of capital losses
On 11 July 2019 the UK government published a summary of responses to the consultation on the restriction of carried forward capital losses, which was held between 29 October 2018 and 25 January 2019. Interested parties submitting responses
See MoreUK: Summary of responses to consultation on digital services tax
On 11 July 2019 the UK government published a document summarising the responses to the consultation on the design of the digital services tax (DST). The DST is to be implemented from April 2020. Certain digital business models derive value
See MoreIMF report comments on Germany’s tax policy
On 10 July 2019, the IMF issued a report following the conclusion of the Article IV consultation with Germany. Germany’s real GDP growth has averaged over 2% for some years but slowed to 1.5% in 2018 owing to reduced global demand and
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