OECD: Report on Improving Tax Certainty Prepared for G20 Finance Ministers
On 23 July 2018 the OECD released a report on approaches to improving tax certainty, prepared for the G20 Finance Ministers who met on 19 and 20 July 2018. The report focuses first on developments in the OECD and G20 countries such as the
See MoreOECD: Tax Report by the Secretary General to the G20 Finance Ministers
On 23 July 2018 the OECD released the tax report from the OECD Secretary General to the G20 Finance Ministers. The G20 Finance Ministers met on 19 and 20 July 2018. Tax Challenges Arising from Digitalisation An interim report issued in March
See MoreIndia: CBDT signs first ever substantive revision to India-UK Bilateral APA
Recently, the Central Board of Direct Taxes (CBDT) signed the first ever substantive revision to an India-U.K. Bilateral advance pricing agreement (APA) due to certain changes in the way a particular transaction was being conducted. The changes were
See MoreRussia: Parliament considering the Bill amending CFC and other rules
Recently, the Russian lower house of parliament considering the Bill No. 442400-7, which includes various measures. The Bill includes following measures: 1. Adjust the CFC rules so that a person will not be recognized as a controlling person of a
See MoreIreland updates CbC Report submission guideline
On 19 July 2018, Irish revenue authority published a Tax and Duty Manual Part 38-03-21 to confirm that requests for technical support in relation to Country-by-Country Reporting must be submitted to Revenue using MyEnquiries through the Revenue
See MorePeru enacts new tax legislation for a short period
Peru’s Congress enacted Law 30823 on 19 July 2018 granting President Power to enact new tax legislation for a short period on specific issues. The President has 60 calendar days till 17 September 2018 to issue new tax legislation. The issues are
See MoreItaly publishes guidance on clarifying application of R&D tax credit
The Italian tax authority during 2018 issued guidance to clarify application of the existing tax rule of Research and Development (R&D) tax credit for eligible Italian companies and Italian permanent establishments of foreign companies investing
See MoreNetherlands submits legislative proposal to implement ATAD postponed
The Secretary of State for Finance has forwarded Letter no. 2018-0000119097 to the Lower House of Parliament on 13th July 2018, announcing that the legislative proposal to implement the EU's Anti-Tax Avoidance (EU) Directive 2016/1164 (2016) (ATAD1)
See MoreAustria: Parliament approves Exchange of CbC Reports and Financial Account Information
On 11 July 2018, the Federal Council (upper house of parliament) of Austria adopted two declarations as approved by the National Council (lower house) on 4 July 2018. The two declarations are relating to the effective date of the multilateral
See MorePuerto Rico publishes extended date for filing annual corporate reports for 2017
The Secretary of State published Administrative Order 2018-04 (AD 2018-04) on 16th July 2018, extending the due date from 18th July 2018 to 17th October 2018 for the filing of the 2017 annual corporate reports.This additional extension only applies
See MoreRussia: The Lower House of Parliament Approves Bill Amending Tax Administration
On 18 July 2018, the Russian lower house of parliament adopted the Bill No. 249505-7 on improving tax administration in the third and final reading. The Bill includes following measures: Eliminate transfer pricing control (audit) for domestic
See MoreUruguay: Directorate General of Taxation amends R&D tax incentive regime
Recently, the Directorate General of Taxation has published Law No. 19.637 with numerous tax amendments. The major change incorporated in the area of incentive regime that provides an exemption for income derived from Research & Development
See MoreNew Zealand’s taxation act regarding Neutralising Base Erosion and Profit Shifting receives royal assent
New Zealand's Taxation (Neutralising Base Erosion and Profit Shifting) Act received royal assent on 27 June 2018. The main measures of the Act are summarized as follows: CbC reporting requirement: According to the published guidance on
See MorePuerto Rico: Treasury Department defines extended timeline for filing returns 2017
The Treasury Department of Puerto Rico (PRTD) has explained (Informative Bulletin 18-14) the due dates for taxpayers who have submitted automatic renewal filings for filing income tax returns for 2017. Calendar year-end taxpayers who submitted an
See MoreUS: IRS issues new transfer pricing examination guide
On 29 June 2018, Treaty and Transfer Pricing Operations (TTPO) of the Large Business and International (LB&I) division of the IRS released the Transfer Pricing Examination Process (TPEP) for use in transfer pricing examinations. Transfer Pricing
See MoreLuxembourg: Government submits a bill for ratification of the MLI to parliament
On 3 July 2018 the Luxembourg government submitted the bill for ratification of the Multilateral Instrument (“MLI”) to parliament. On 15 June 2018, the Cabinet was approved this bill for ratification of the Multilateral Instrument
See MoreLithuania ratifies multilateral convention to implement tax treaty related measures to prevent BEPS (MLI)
On 14 June 2018, Lithuania ratified the Multilateral Convention to Implement Tax Treaty Related Measures to Prevent BEPS (MLI) by the Law No. XIII-1271, as published in the Official Gazette on 26 June 2018. This means that Lithuania has completed
See MoreIreland publishes tax and duty manual on loans applied in acquiring an interest in a company
On 16 July 2018, Irish revenue authority published a Tax and Duty Manual concerning loans applied in acquiring an interest in a company. The contents of Tax and Duty Manual Part 08-05-02 - Loans applied in acquiring an interest
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