Colombia publishes new thin capitalization rule
On 26 June 2019, the Government of Colombia published a Decree 1146 of 2019, concerning the new thin capitalization rules which amended the previous law 1943 of 2018. The new Decree 1146 of 2019 includes the following measures: The thin
See MoreWorld Bank approves grant to improve domestic revenue mobilization in Liberia
On 16 July 2019 the World Bank approved a grant to its International Development Association (IDA) to improve domestic revenue mobilization systems and strengthen financial control and accountability in public finances. The IDA provides grants and
See MoreOECD and Brazil: Report on project to align transfer pricing rules with OECD standards
On 7 July 2019 the OECD and Brazil’s tax administration (RFB) published a report on the results of the work programme launched in February 2018 to analyse Brazil's transfer pricing framework and the similarities and divergences between the
See MoreIndonesia: MoF changes CFC deemed dividend rules
On 26 June 2019, the Ministry of Finance published a new regulation (No.93/PMK.03/2019(PMK-93) on the controlled foreign corporation (CFC) rules for fiscal year(FY) 2019 which amended the regulation No.107/ PMK.03/2017(PMK-107), concerning the
See MoreLatvia publishes regulations for low value-adding intra-group services
On 9 July 2019, Latvia published Cabinet Regulations No. 324 of 9 July 2019 in the Official Gazette addressing simplified transfer pricing provisions for intra-group low value-added services. The Regulation provides that the general
See MoreAlgeria: DGI issues a guideline on electronic tax declaration
The Algerian tax agency Direction Generale des Impots (DGI) has recently published a guideline on electronic tax declaration and payment procedures. The guideline provides the following information: requirements to access the electronic
See MoreDenmark implements EU dispute resolution directive
The Act implementing Council Directive (EU) 2017/1852 of 10 October 2017 in Denmark entered into force on 30 June 2019. The Directive contains provisions on the effective resolution of disputes concerning the interpretation and application of
See MoreGreece: Tax authority clarifies the limitation period for the late filing of tax return
On 1 July 2019, the tax authority published the Circular E.2123 explaining the application of the limitation period in the event of late filing of a tax return. The new Circular amends Circular 1165/2018 in relation to the limitation period of 15
See MoreFrance issues new guidelines for GAAR
On 3 July 2019, the tax authorities published a guidelines regarding the new general anti-abuse rule (GAAR). The new GAAR, which applies from 1 January 2019, targets provisions that focus on tax-driven abuses of law. According to the guidance,
See MoreIceland: MOF Seeks Comments on draft CbC reporting regulations
On 12 July 2019, the Ministry of Finance and Economic Affairs has opened a public consultation on draft CbC reporting regulations. The draft regulation includes the measures outlining the income, taxes, and economic activities of multinational
See MoreEcuador: SRI issues decree on advance income tax payments
On 5 July 2019, the Ecuadorian Internal Revenue Service (Servicio de Rentas Internas-SRI) issued Executive Decree No. 806 of 25 June 2019 in its official website. The decree introduces new schedule for advance income tax payments. The payment of
See MoreUS: IRS updates instructions for Country by Country reporting form
On 10 July 2019, IRS published the updated instructions for filing Form 8975 (Country-by-Country Report). Key changes are highlighted below; IRS Updates Mailstop for U.S. MNEs Filing Form 8975 on Paper: If a U.S. multinational enterprise
See MoreBrazil updates its blacklist removing San Marino
On 28 June 2019, The Department of Federal Revenue (RFB) of Brazil has published Normative Instructions No. 1896 of 27 June 2019 in the official gazette amending Normative Instructions Nº 1037. Through the instruction RFB removes San Marino from
See MoreUkraine: SFS clarifies treatment of controlled transactions with Bulgaria
On 20 June 2019, the Ukraine State Fiscal Service published a guidance letter No. 2826/6/99-99-15-02-02-15/IPC defining the treatment of transactions with residents of tax Bulgaria, which was removed from the Cabinet tax haven list in April
See MoreSweden transposes EU Directive on Dispute Resolution
On 19 June 2019, a law proposal that implements the EU Tax Dispute Resolution Directive (2017/1852) was presented to the parliament to be transposed into Swedish legislation. If passed, the law will enter into force on November 1,
See MoreBolivia issues resolution for tax certificates procedure
On 29 June 2019, Bolivian National Tax Service issued Resolution No. 101900000011 in the official website introducing procedure and requirement for certificates of tax residence, tax debt, and foreign accreditation. The resolution clarifies the
See MoreBangladesh enacts Budget for 2019-20
On 30 June 2019, Parliament passed the Tk 5,23,190 crore national budget for 2019-20 fiscal year. The proposals were enacted by the Finance Act, 2019 (the Act) and became effective as of 1 July 2019. The summary of key amendments introduced by
See MoreNetherlands: Cabinet submits new bill against tax avoidance
The Dutch government published a legislative proposal engaging rules to counter hybrid mismatches into the Dutch corporate income tax act pursuant to the EU Anti-Tax Avoidance Directive as agreed upon in May 2017 (ATAD2). ATAD2 would address tax
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