Slovenia approves amendments to the Corporate Income Tax Act
On 23 October 2019, the Slovenian government adopted amendments to the Corporate Income Tax Act. The amendments are following: The Corporate income tax is increased from 19% to 20%;A minimum corporate tax at a rate of 7% is introduced which
See MoreGreece: AADE publishes Circular E. 2183 of 10 October 2019 on limitation of interest payments
On 10 October 2019, the Greek Revenue Authority (AADE) published Circular E. 2183 of 10 October 2019 on the deductibility of interest payments that have been grossed-up to include the tax amount. The circular describes that the tax paid is
See MoreCzech Republic: Parliament debates proposed changes to Income Taxes Act
The Chamber of Deputies debate with some changes to the Income Taxes Act, which may come into force in 2020. The measures must be approved by the Chamber and the Senate and signed by the president before coming into force. The provisions of the
See MoreNorway proposes to amends interest deduction limitation rules and R&D incentive scheme
On 7 October 2019, the Ministry of Finance presented its budget proposal for fiscal year 2020. The budget proposed to amends the interest expense deduction limitation rules and the Norwegian research and development (R&D) incentive scheme.
See MoreIreland: Finance Minister announces Finance bill for the year 2020
On 16 October 2019, the Finance Minister, Paschal Donohoe TD, announced Cabinet approval for the publication of the Finance Bill 2019. It was published on 17 October 2019. The Bill sets out the legislative provisions to bring effect to the tax
See MoreBulgaria: Draft Law on implementation of hybrid mismatch and exit tax measures submits to NA
On 9 October 2019, a draft Law on “Amendment and Supplementation of the Corporate Income Tax Act” was presented to the National Assembly (NA). The bill proposes provisions transposing the exit taxation measures of the EU Anti-Tax Avoidance
See MoreIreland: Govt. announces draft budget 2020
On 8 October 2019, Govt. announced draft Budget 2020. This draft Budget introduced some amendments in respect of corporate income tax, transfer pricing, dividend withholding tax, personal income tax, small and medium enterprises (SMEs),
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 MoreNetherlands: Budget proposal for 2020
On 17 September 2019, the Dutch Government published the 2020 budget proposals, which includes the Tax Plan for 2020. The 2020 Tax Plan package consists of the following six bills: the 2020 Tax Plan Bill;the Other 2020 Tax Measures
See MoreAustralia updates guideline for simplified transfer pricing record keeping options
On 11 September 2019, the Australian Taxation Office (ATO) released an updated version of Practical Compliance Guideline (PCG) 2017/2 concerning the eligibility criteria for applying simplified transfer pricing record keeping options for
See MoreVietnam clarifies the limitation of the deductibility of loan interest expense for TP purposes
On 11 September 2019, the Department of Taxation of Ha Noi City issued Official Letter No. 71443/CT-TTHT providing clarification on the determination of loan interest costs. Under article 8 (3) of Decree No 20/2017 / ND-CP, the total loan
See MoreMexico: Tax reform proposal in economic package 2020
On 8 September 2019, Mexican president Andrés Manuel López Obrador’s presented Economic Package for the fiscal year 2020 to Congress. The economic package proposed following tax reform measures: Transparent Entities International
See MoreUK amends hybrid capital instruments rules
The ‘hybrid capital instruments’ rules are relied upon since 1 January 2019 by many banks and insurers to give corporation tax relief for the coupon payments on regulatory capital securities. These rules have recently been amended by the
See MoreFrance: Tax Authority issues a Ruling on interest deduction
The tax authority issued a ruling regarding the deductibility of interest paid to a related Belgian company benefiting from the notional interest regime. On 4 September 2019, the French General Directorate of Public Finance clarified that tax
See MorePoland: Ministry of Finance publishes a draft bill to implement EU ATAD 2 anti-hybrid measures
On 23 August 2019, the Poland Ministry of Finance released a draft bill outlining several provisions to implement EU ATAD 2 anti-hybrid measures. The main purpose of implementing the anti-hybrid measures is to counteract the situation of double
See MoreAustralia: ATO compliance approach to the arm’s length debt test
On 28 August 2019, the Australian Taxation Office (ATO) published draft Practical Compliance Guideline PCG 2019/D3, which sets out the proposed compliance approach for the use of the arm’s-length debt test (ALDT) for the purposes of
See MoreLuxembourg: Government submits EU Anti-Tax Avoidance Directive to Parliament
On 9 August 2019, Luxembourg Government submits draft law to the Parliament for the execution of the expanded hybrid mismatch rules of the European Union (EU) Anti-tax Avoidance Directive as amended (ATAD2). The draft law aims at broadening the
See MoreHungary publishes legislation implementing EU directive on hybrid mismatch rules
On 23 July 2019, Hungary published a legislation through an official gazette that provides for the implementation of exit tax and hybrid mismatch rules of the EU Anti-Tax Avoidance Directive (ATAD). On 12 July 2019, the Hungarian legislator passed
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