Denmark publishes the Bill no. L 48 on international taxation
On 6 November 2019, the Danish Minister of Taxation published Bill no. L 48 on international taxation. The bill updated the existing PE (permanent establishment) rules, CFC rules and strengthen the Transfer pricing (TP) rules. PE rules: The
See MoreBulgaria approves changes to the TP documentation threshold
On 21 November 2019, the Bulgarian parliament approved amendments to the thresholds for mandatory preparation of a local transfer pricing file. According to the amendments, the obligation to prepare such documents from 1 January 2020 will not
See MoreUS: IRS issues a notice requesting comments on CbC form
On 6 November 2019, the US Internal Revenue Service (IRS) published a notice requesting comments concerning IRS Form 8975 regarding CbC report. The Internal Revenue Service, as part of its continuing effort to reduce paperwork and respondent
See MoreCyprus amends the company law introducing administrative penalties
On November 1, 2019, the Registrar of Companies published a notice regarding the implementation of Law 149 (1) / 2018 (the Act). The law amends company law and company law regulations with the introduction of administrative penalties on certain
See MoreSouth Africa: SARS publishes list of jurisdiction with effective CbC report exchange agreements
The South African Revenue Service (SARS) published a latest list of jurisdictions. These listed jurisdictions have CbC report exchange agreements with South Africa from 18 October 2019. The list is intended to assist members of the MNE groups
See MoreAustralia extends TP document submission deadline
Significant global entities (SGEs) that have a CbC reporting obligation in Australia for the year ended 31 December 2018 required that their local file (LF), master file (MF), and CbC report are due to be lodged by 31 December
See MoreCosta Rica publishes a resolution outlining guideline on transfer pricing documentation
On 13 November 2019, the Costa Rican tax authority released a Resolution No.DGT-R-49-2019 providing new guidelines on transfer pricing documentation including master file and local file. The new resolution repeal the resolution DGT-R-16-2017
See MoreSerbia: Parliament adopts draft bill to implement CbC reporting obligations
On 18 October 2019, the Serbian parliament accepted for consideration a bill to implement country-by-country (CbC) reporting obligations for multinational entities (MNEs). Under this ultimate parent entities of an MNE group resident in Serbia are
See MoreBulgaria submits proposal to amends the TP documentation threshold
On 12 November 2019, some of policy makers submitted to Parliament a proposal to amend the rules on thresholds for the Transfer Pricing (TP) documentation rules. It is proposed that the obligation to prepare such documents will not apply to persons
See MoreDominican Republic: Executive Branch submits 2020 draft budget bill to the National Congress
On 1st October 2019, the Executive Branch sent 2020 draft budget bill to the National Congress the 2020 draft budget bill for its knowledge, discussion and approval. The bill proposes measures to extend the rules on interest deduction and
See MoreSlovak Republic: Implementing mandatory disclosure rules
On 14 October 2019, the Government of Slovak Republic published in the Collection of Laws the final legislation that transposes the Directive on Administrative Cooperation in Taxation (DAC6) commencing Mandatory Disclosure Rules (MDR). On
See MorePeru: SUNAT publishes resolution on submission of CbC reports
On 29 September 2019, the Peruvian Tax Administration (SUNAT) has published Resolution No. 188-2019/SUNAT in the Official Gazette, through which the comprehensive system for the reception and automatic exchange of information (IR AEOI system) was
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 MoreNigeria: FIRS introduces e-filing for submitting TP returns
On 27 September 2019, Federal Inland Revenue Service (FIRS) described the way of how to submit transfer pricing (TP) returns through the electronic platform, when it is active. Now, the FIRS is get ready to automate the process of filing TP
See MoreGreece: AADE publishes Circular 1341 / 09-09-2019 on CbC notification process
On 17 September 2019, the Greek Public Revenue Authority (AADE) released a Circular 1341 / 09-09-2019 containing amendments to Decision POL. 1184 of 22 November 2017 regarding the submission process of CbC notifications. Under this new Circular,
See MorePortugal publishes changes to various Tax Codes
On 18 September 2019, the Portuguese Government officially published the Law no.119/2019. The new law has changed the following provisions: Corporate income tax: The procedure whereby non-resident companies may waive all or part of the
See MoreDenmark: Draft bill on international taxation submits for public comments
On 12 September 2019, the Ministry of Taxes published a major bill on international taxation. The bill will be subjected to a public hearing and subsequently presented to the Danish Parliament. Interested parties can submit their comments by 10
See MoreSaudi Arabia: GAZT requests for TP documentation
Recently, the General Authority of Zakat and Tax (GAZT) of Saudi Arabia have requested the taxpayers to submit specific transfer pricing (TP) documentation (master file and local file) in relation to the fiscal year ending 31 December
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