Poland publishes explanatory note addressing transfer pricing comparability analyses
On 19 June 2019, Poland Ministry of Finance published an explanatory note addressing transfer pricing comparability analyses. Accordingly, database for comparables could be selected locally, regionally, or even globally by considering
See MorePortugal approves MLI
On 21 June 2019, the Portugal's parliament approved the resolution for the ratification of the Multilateral Convention to Implement Tax Treaty Related Measures to Prevent Base Erosion and Profit Shifting (MLI). After the ratification process,
See MoreSouth Africa: Tax benefits for investors through Section 12J VCC regime
In 2009 Government implemented a tax incentive for investors in privately owned entrepreneurial businesses in South Africa to assist small and medium sized enterprises (SMEs) with access to equity finance. Individuals, companies and trusts (any SA
See MoreIndonesia: MOF proposes draft amendments to the SEZ scheme and tax cuts
The Indonesian Ministry of Finance (MoF) published two announcements on June 17 and 20 June 2019. The ministry is reviewing draft amendments to the Special Economic Zones (SEZ) regime and tax cuts for specific sectors. SEZ regime: Under this
See MoreUruguay: New incentive for software development
Uruguay has published Decree No 96/2019 of 22 April 2019 amending exemption incentive for software development with effect from 1 January 2018 to comply with BEPS Action 5. The decree applies retroactively from 1 January 2018. The Decree
See MoreRussia proposes Transfer Pricing and MAP-related changes
The Russian Ministry of Finance has proposed some transfer pricing amendments (Draft legislation No. 720839-7) and submitted them to the State Duma for approval (preliminary examination of the draft law submitted to the State Duma). The draft law
See MoreSaudi Arabia: GAZT holds seminar to simplify the transfer pricing regulations
On 17 June 2019, the General Authority of Zakat and Tax (GAZT) of Saudi Arabia has organized a transfer pricing seminar in Riyadh to simplify the key areas of the transfer pricing (TP) regulations published on 15 February 2019 and to address
See MoreNetherlands: Consultation on tax group regime
The Finance Ministry of the Netherlands has announced the launch of a public consultation on the design of a new corporate tax group regime to replace the current fiscal unity regime. The consultation includes four possible
See MoreSlovak Republic approves a draft law to update income tax act
On 29 May 2019, the Slovak government approved a draft Law to update the Income Tax Act. The draft law proposes the implementation of Directive 2017/952 amending Directive 2016/1164 as regards hybrid mismatches with other countries. It also
See MoreRussia: MOF clarifies the ‘related party’ for transfer pricing purposes
Recently, the Russian Ministry of Finance has adopted a guidance letter (No. 03-12-12 / 1/39688 of 05.31.2019) clarifying the recognition of persons as related for transfer pricing purposes. The Guidance Letter No. 03-12-12/1/39688 says that
See MoreRussia deposits ratification instrument for MLI
On 18 June 2019, the Russian Federation has deposited its instrument of ratification for the Multilateral Convention to Implement Tax Treaty Related Measures to Prevent Base Erosion and Profit Shifting (MLI). According to the date of deposit,
See MoreVietnam: NA approves a new taxation regime for Foreign Service providers
On 13 June 2019, the National Assembly (NA) approved the Law on Tax Administration (amended changes). The law introduced a new taxation regime for Foreign Service providers including e-commerce business. This law will take effect from 1 July
See MoreKenya: Finance Minister proposes Budget for the Financial Year 2019/20
On 13 June 2019, the Finance Minister, Henry Rotich of Kenya presented the budget for 2019/20 to the parliament. The budget includes the following tax related measures: Capital Gains Tax is proposed to be increased from 5% to 12.5%. There is
See MoreColombia: DIAN publishes procedures to submit the TP return, Master file, Local file and CbC report
On 22 May 2019, the Colombian tax authority (DIAN) published regulations for the submission of the Local file and Master file, the Transfer pricing (TP) return, and the Country-by-Country (CbC) report notification corresponding to the 2018 tax year
See MoreArgentina: Tax ruling on BEPS Action 5 minimum standard
On 30 May 2019, the Argentine tax authority published General Resolution No. 4497 (GR 4497/2019) in the official gazette amending the binding ruling (as established by Article 4 of Law No. 11,683) regulations, which adapts the Argentine tax
See MoreBelgium updates EU directive on tax dispute resolution
Belgium has published the Law of 2 May 2019, which transposes Council Directive (EU) 2017/1852 of 10 October 2017 on tax dispute resolution mechanisms in the European Union. The directive lays down rules on a mechanism to resolve
See MoreArgentina enacts law on knowledge-based economy
Argentina has published Law 27,506 in the official gazette enacting Decree No. 408/2019 , establishing promotional regime on tax benefits for the Knowledge Economy. The purpose of the law is to the promote of the country’s knowledge-based and
See MoreTanzania: Finance Minister presents Budget for FY 2019/2020
On 13 June 2019, Philip Mpango, the Finance Minister of Tanzania, presented the Budget for financial year (FY) 2019/2020 to the National Assembly. The finance minister said that total domestic revenue including Local Government Authorities (LGAs)
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