Colombia: Constitutional Court rules ‘Tax Reform Law 2019’ as unconstitutional
On 16 October 2019, the Colombian Constitutional Court ruled that the tax reform law 2019 was unconstitutional. The tax reform law 2019 (law No. 1943), which came into force on 1 January 2019, is invalid due to procedural flaws in the approval
See MoreUkraine: STS clarifies on determination of profits attributable to PE
The State Tax Service (STS) of Ukraine issued Letter No. 353/ІPK/15-32-05-04-02-15 of 25 September 2019 regarding determination of profits attributable to permanent establishment (PE). Permanent establishment (PE) will be recognized as an
See MoreNetherlands publishes draft list of low tax jurisdictions
On 7 October 2019, the Government of the Netherlands introduced a consultation on the updated list of low-taxed and non-cooperative jurisdictions. The Dutch government has proposed 4 changes to the list, removing Belize and Saudi Arabia from the
See MoreChile: President presents 2020 draft Budget
The President, Sebastian Pinera, announced draft budget for the year 2020. He said that they have passed a very crucial economic time due to the low copper prices and the trade war between China and the United States. The draft budget covers
See MoreNorway revises list of low tax jurisdictions
On 26 September 2019, Norway published a regulation amending the list of low tax jurisdictions for tax purposes. The list applies both to taxation of income and losses on investments in low-tax countries. The countries which are considered as
See MoreArgentina: AFIP announces draft transfer pricing guidance for public comments
On 2 October 2019, tax authority of Argentina (AFIP) announced a public consultation and posted on the AFIP website a draft resolution concerning transfer pricing compliance procedures. It would replace the existing transfer pricing rules in
See MoreFrance: Government presents draft Finance Bill 2020
On 27 September 2019, Government presents Finance Bill for the year 2020 and confirms the willingness to cut the income tax rate for corporate entities; to introduce the hybrid mismatch rules; to implement the EU ATAD 2 directive into domestic law;
See MoreMalaysia withdraws withholding tax exemptions available to MSC Malaysia status companies
Malaysia Digital Economy Corporation Sdn Bhd (MDEC) has recently announced on its website that the withholding tax (WHT) exemption on certain types of income received by a non-resident company from an approved Multimedia Super Corridor (MSC)
See MoreUS: IRS publishes final and proposed regulations on new 100% depreciation
On 13 September 2019, the Treasury Department and the Internal Revenue Service published final regulations and additional proposed regulations under section 168(k) of the Internal Revenue Code on the new 100% additional first year depreciation
See MoreHong Kong: IRD updates penalty provisions for international tax
On 4 September 2019, the Hong Kong Inland Revenue Department updated its web page on penalty policies related to international tax matters, including fines and criminal penalties, for noncompliance with international tax obligations. The
See MoreSaudi Arabia: GAZT publishes Tax Ruling Requests guide
Recently, the General Authority of Zakat and Tax (GAZT) of Saudi Arabia published the English version of Tax Ruling Requests guide. The tax ruling guide includes the following measures: An applicant can apply for a Ruling when it is unsure
See MoreUganda: Parliament passes Income Tax (Amendment) Act 2019
On 30 June 2019, Ugandan Parliament has passed Income Tax Amendment Act 2019. The act contains a number of measures including definition of beneficial owner to reduce the threshold required for exemption; to provide for withholding tax by a seller
See MoreColombia 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 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 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 MorePeru: SUNAT publishes new tax guidance on indirect transfers for entities
On 4 June 2019, the Peruvian tax authority (SUNAT) published new guidance (Informe No. 046-2019-SUNAT/7T0000) for the determination of the market value of shares in relation to the rules for the taxation of the indirect transfers of shares in
See MoreArgentina issues decree regarding exemption to the tax on debits and credits
Argentina issued Decree No. 373/2019 on 27 May 2019, which includes new exemption from tax on debits and credits for those accounts used for the provision of financial services by complementary financial services agencies. The decree was issued
See MoreIndonesia: MoF publishes new guidance on MAP
On 26 April 2019, the Minister of Finance (MoF) issued a new provision on the Mutual Agreement Procedure (MAP) with Regulation No. 49 / PMK.03 / 2019 (PMK-49). PMK-49 is effective from 26 April 2019 and repeals MoF Regulation No. 240 / PMK.03 /
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