Belgium approves MLI
On 21March 2019, the Parliament of Belgium approved the law ratifying of the Multilateral Convention to implement double taxation avoidance agreement related measures to prevent Base Erosion and Profit Shifting (BEPS). After the
See MoreIndia: ITAT ruled that the income which is deemed to accrue or arise in India must have a territorial nexus
Recently, the Mumbai Bench of the Income-tax Appellate Tribunal (ITAT) in the case of: Fox International Channel Asia Pacific Ltd v. DCIT (ITA No.1947/Mum/2015) regarding the taxability of agency commission relating to the services rendered outside
See MoreSwitzerland approves MLI
On 22 March 2019, the Swiss Parliament approved in the final vote the ratification of the multilateral convention to implement tax treaty related measures to prevent Base Erosion and Profit Shifting (MLI). The MLI is subject to an
See MoreZambia publishes Budget for 2019
On 1 January 2019, The Zambian government published budget for 2019 to the National Assembly. Key modifications of tax rules are summarized as follows: Limit the deductibility of interest on debts owed by a taxpayer to 30 % of the
See MorePeru: SUNAT extends the deadline for submission of CbC reports for fiscal years 2017 and 2018
On 14 March 2019, the Peruvian tax authorities (SUNAT) issued an administrative regulation (Ruling No.054-2019) that extends the deadlines for the local filing of the CbC reports for Fiscal years 2017 and 2018. This resolution is effective as of the
See MoreRussia: Parliament proposes to reduce the corporate property tax rate
On 6 March 2019, a draft bill was presented to the State Duma (Lower House of Parliament) proposing to lower the maximum amount of the property tax rate to be taxed at the cadastral value. According to the bill, the corporation tax rate for real
See MoreSerbia: Ministry of Finance publishes safe harbor interest rates for 2019
The Serbian ministry of finance has published the Rulebook on arm’s length interest rates that are applicable for 2019, which apply to interest rates on loans and credits between associated parties. The Rulebook was published in the Official
See MorePuerto Rico extends the due date for filing 2018 informative returns
On 27 February 2019, The Puerto Rico Treasury Department issued Internal Revenue Informative 19-06 to extend the filing date this year to 15 March 2019. The provisions of Bulletin No.19-06 are effective as from 27 February 2019. Pursuant to Sections
See MoreColombia: Tax Authority updates forms for filing tax returns in 2019
On 7 March 2019, the National Tax Authority (DIAN) of Colombia published an administrative regulation and updated the withholding tax return forms (Form 350) for 2019. According to Annex 2, the following payments are made to resident in
See MoreCanada: Federal budget 2019
On 19 March 2019, Finance Minister Bill Morneau tabled in the House of Commons the Liberal Government’s Budget 2019. This budget focuses on continued economic growth, job creation, support for first-time home buyers, investments in cleaning up
See MoreIndia: ITAT decision on criteria for selecting transfer pricing comparable companies
The Kolkata Bench of the Income Tax Appellate Tribunal (ITAT) in the case of: Philips Medical Systems (P.) Ltd. v. ITO, held that an entity engaged in both manufacturing and trading activities cannot be a comparable company for benchmarking the
See MoreLuxembourg: Finance Minister presents draft budget law for 2019
On 5 March 2019, the Luxembourg Minister of Finance, Pierre Gramegna, presented to the Chamber of Deputies the draft budget law 2019 together with the draft multi-annual financial planning, for the 2019-2022 period to the Chamber of Deputies. The
See MoreNigeria: FIRS issues guidance on MAP
On 21 February 2019, Nigeria’s Federal Inland Revenue Services (FIRS) has issued guidelines on Mutual Agreement Procedure (MAP). The guidelines prescribe information regarding eligibility for MAP, access to MAP, overview of the MAP request
See MoreFinland: Tax administration publishes guidelines on interest limitation rules
On 7 March 2019, the Finnish tax administration published new guidelines on the rules on interest deduction restrictions, which were amended to comply with EU Anti-Tax Avoidance Directive (ATAD), and contained a general 25% EBITDA interest deduction
See MoreAustralia: New guidance related to inbound distribution arrangements
On 13 March 2019, the Australian Taxation Office (ATO) released a PCG 2019/1 for all multinational enterprises (MNEs) with distribution operations in Australia. This Guideline outlines compliance approach to the transfer pricing
See MoreUK: Spring Statement 2019
The Chancellor delivered the Spring Statement on 13 March 2019. There were no major tax announcements owing to the uncertainty currently surrounding the UK’s withdrawal from the European Union. UK economic growth is to fall to 1.2% for 2019,
See MoreQatar: New guidance on submitting income tax returns
On 4 March 2019, Qatar's General Tax Authority (GTA) released Circular No. 1/2019 referring to Article 11 of tax law 24 of 2018 and clarifies guidance on submitting income tax returns. The circular informs that taxpayers need to submit their tax
See MorePakistan approves the Finance Supplementary (Second Amendment) Bill, 2019
On 6 March 2019, the National Assembly has approved the Finance Supplementary (Second Amendment) Bill, 2019 aimed at amending tax laws. The major changes introduced to income tax laws are as follow: -For nonbanking sectors, the super tax is
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