Malaysia: IRB releases Transfer Pricing audit framework for 2019
On 15 December 2019, the Malaysian Inland Revenue Board (“MIRB”) published the TP audit framework (2019). The Transfer Pricing Audit Framework 2019 is effective from 15 December 2019 and replaces the Transfer Pricing Audit Framework 2013 which
See MoreTurkey: Parliament passes laws on tax regulation
On 21 November 2019, the Turkish Parliament approved laws on tax regulation which includes new taxes, namely digital services tax (DST), valuable house tax and accommodation tax. The law increases tax rate from 30% to 40% for people earning
See MoreColombia: MinHacienda issues decree on taxation of investment funds and PEs
On October 29, the Colombian Ministry of Finance and Public Credit (MinHacienda) has issued Decree 1973, which clarified measures regarding the taxation of private equity funds and collective investment funds and rules on the attribution of income
See MoreUS: Treasury department issues regulations removing documentation requirements
On 31 October 2019, the US treasury department issued final regulations (TD 9880), repealing section 385, which sets out minimum documentation requirements that must normally be met in order for certain related-party interests in a corporation to
See MoreAustria: The upper house approves the tax on digital advertising
On 10 October 2019, the upper house of Austria's Parliament passed a digital advertising tax bill. The bill was approved by the Austrian lower house of Parliament on 19 September 2019. The Bill includes the following changes: Under the Digital
See MoreFrance: Government publishes transposition order of DAC6
On October 22, 2019, Government published a French Ordinance No. 2019-1068 of 21 October 2019, regarding the Automatic and Compulsory Exchange of Information in the Field of Taxation in Relation to Cross-Border Devices for Reporting. The EU
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 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 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 MoreKenya: KRA releases a notification on taxation of e-commerce
On 3 May 2019, the Kenya Revenue Authority (KRA) published a public notification on the taxation of e-commerce regarding some taxpayers carry on online business and they do not file returns or pay taxes on the transactions. The tax authority
See MoreMexico publishes Annexes to Miscellaneous Tax Resolution 2019
On 29 April 2019, Annexes of the Miscellaneous Tax Resolution for fiscal year 2019 (Resolución Miscelánea Fiscal para 2019, RMF 2019) were published in the Official Gazette published. The location of the administrative units of the Tax
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