UK: Public consultation on hybrid mismatches rule
On 19 March 2020, the tax authority the United Kingdom has issued a consultation document for public comments on the impact of the double deduction rules and the acting together rules within the hybrid and other mismatches regime at Part 6A of the
See MoreSouth Africa: Finance Minister delivers draft Budget for 2020-2021
On 26 February 2020, the Finance Minister, Tito Mboweni, delivered National Budget for the year 2020-2021. Some provisions of budget 2020-2021 include: Corporate income tax The standard corporate income tax rate was proposed to remain
See MoreLatvia implements EU ATAD hybrid mismatch measures
On 11 February 2020, Latvia published the Law of 30 January 2020 on Amendments to the Corporate Income Tax Act in the official gazette. The law includes the provision for the implementation of the hybrid mismatch measures of the EU Anti-Tax
See MoreEstonia implements EU ATAD 2 from 1 January 2020
Estonia has implemented the EU Anti-Tax Avoidance Directive (2017/952) (ATAD 2). ATAD 2 amends the EU Directive 2016/1164 which extends the scope of the Hybrid Mismatches Rules to a wider range of transactions and also to apply to transactions with
See MoreMalta amends EU ATAD Implementation Regulations
Recently, Malta has published Legal Notice No. 29 of 2020 in the Official Gazette amending Regulation 10 of the EU Anti-Tax Avoidance Directives (ATAD) Implementation Regulations. The Regulation states that the reverse hybrid rules will apply from
See MorePoland: Council of Ministers submit ATAD2 hybrid mismatch measures to parliament
On 5 February 2020, Poland's Council of Ministers submitted some tax measures in parliament including the hybrid mismatch measures of the EU Anti-Tax Avoidance Directive as amended (ATAD2). ATAD2 would address tax avoidance through hybrid
See MoreUkraine: Parliament approves draft law to implement BEPS provisions
On 16 January 2020, the Ukrainian Parliament approved draft laws on the improvement of the administration of taxes and elimination of certain inconsistencies in tax legislation (Law No 1209-1 and Law No 1210) to implement the Base Erosion and
See MorePortugal: Draft bill to implement ATAD1 and ATAD2
On 30 January 2020, a draft bill was presented to the Parliament for the execution of the hybrid mismatch rules of the EU Anti-Tax Avoidance Directive and the Directive as amended (ATAD1 and ATAD2). This consists of measures to counter hybrid
See MoreBosnia and Herzegovina: Government adopts Law on Profit Tax
On 16 January 2020, Government adopted the amendment in Law on Profit Tax. The Law proposed to exclude leasing companies from the interest deduction limitations provisions. On the other hand, this Law stated that income statements are not necessary
See MoreIreland: President signs Finance Bill 2019 into Law
On 22 December 2019, President, Michael D. Higgins, signed the 2019 Finance bill into law. This Finance Act 2019 implements the taxation changes announced on Budget, including new transfer pricing legislation, introducing some necessary
See MoreMalta implements EU ATAD 2 hybrid mismatch provisions
On 24 December 2019, Malta has published Legal Notice 348 of 2019 implementing EU Anti-Tax Avoidance Directive (2017/952) (ATAD 2) into Malta domestic law. ATAD 2 amends the EU Directive 2016/1164 which applies to mismatches between EU member
See MoreCroatia: Government publishes tax reform effective as from 1 January 2020
On December 11, 2019, the Croatian Government published Law in the Official Gazette to require taxpayers/ intermediaries to report information on certain tax arrangements. Some of the changes are given below: Corporate income tax/Profit
See MoreBelgium enacts amended interest deduction limitation rule
On 27 December 2019, a royal decree of 20 December 2019 published in Belgian official journal introduces several changes to the interest deduction limitation rule in the Income Tax Code, often referred to as the 30% earnings before interest, tax,
See MoreNigeria: President signs Finance Bill 2019 into Law
On 13 January 2020, the President, Muhammadu Buhari, signed the 2019 Finance bill into law. It was submitted alongside the 2020 budget to the National Assembly. The new law contains over 90 changes to 7 different tax laws. Corporate income
See MoreFrance: Government officially publishes Finance Act 2020
On 29 December 2019, Government published 2020 Finance Bill in the Official Gazette after the Court’s approval. Corporate income tax The Finance Act reduces the corporate tax rate for all companies, including those with a turnover of €
See MoreGermany publishes draft bill to implements ATAD hybrid mismatch rules
On 10 December 2019, the German Ministry of Finance issued a draft bill to implement the anti-tax avoidance directive (ATAD) including Hybrid mismatch rules. The hybrid mismatch rules will apply from 1 January 2020 to address double deduction
See MoreEcuador: Government publishes tax reform for 2020
On 31 December 2019, the Government published tax reform 2020 through Law of Simplicity and Tax Progressivity (Law No. SAN-2019-1270) in the Official Gazette. The Law effects from 1 January 2020. Some of the key provisions are given
See MoreFinland: President sign the law to implement the EU directive on hybrid mismatch rules
On 30 December 2019, the President of Finland signed the Law 1567/2019 that provides for the implementation of the hybrid mismatch rules of the Anti-Tax Avoidance Directive, as amended by Council Directive (EU) 2017/952 (ATAD2). The hybrid
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