Denmark: Ministry of Taxation publishes bill to implement EU ATAD
On 28 December 2018, the Danish Ministry of Taxation has published a new legislation (Law No 1726) for the implementation of the measure of the EU Anti-Tax Avoidance Directive (ATAD1) and the Directive as amended (ATAD2). The measures
See MoreUS: IRS publishes proposed regulations on certain hybrid arrangements
On 20 December 2018, IRS issued proposed regulations implementing sections 245A(e) and 267A that were added with the enactment of the Tax Cuts and Jobs Act (TCJA). The proposed Regulations concern sections 245A (e) and 267A relating to hybrid
See MoreItaly releases ATAD decree in line with EU Anti-Tax Avoidance Directive
On 28 December 2018, the Italian Government published, in the Official Gazette, the Legislative Decree (Decree) transposing the European Union (EU) Anti-Tax Avoidance Directive (ATAD) in the Italian legislation. The Government had previously
See MoreEstonia implements EU ATAD measures
On 28 December 2018, Estonia published the Income Tax Amendment Act in the Official Gazette, apply from 1 January 2019. The key measures of the Act provide the implementation of the EU Anti-Tax Avoidance Directive (ATAD) as urged by the European
See MoreRomania updates CFC and restriction on interest deduction rules
Romania has published Law no. 30 of 10 January 2019, which amendments restriction on interest deduction rules. The amendments increase safe harbor threshold from the RON equivalent of EUR 200,000 to the RON equivalent of EUR 1 million. It also
See MoreFinland: Ministry of Finance publishes law on interest restriction rules
On 27 December 2018, Finland published Law 1237/2018 in the Official Gazette concerning new interest deduction restriction rules that are compliant with the EU Anti-Tax Avoidance Directive (ATAD). The law extends the limitation to interest paid on
See MoreJapan proposes tax reform plans for 2019
On 14 December 2018, Japan's ruling coalition party has approved a package of tax reform proposals for 2019. The proposal includes amendments to Japan’s controlled foreign company (CFC), interest expense limitation, and general transfer pricing
See MoreLuxembourg: Parliament passes draft law implementing EU Anti-Tax Avoidance Directive
On 18 December 2018, the Luxembourg Parliament passed draft law No 7318 (the Law) implementing the EU Anti-Tax Avoidance Directive (ATAD), which sets out limitation to interest deductibility, the provisions on controlled foreign companies ( CFC) and
See MoreArgentina enacts regulation to implement the tax reform
On 4 December 2018, Argentina enacted Law 27,430 (the Act), which contains proposals for the implementation of the tax reform. The law introduced the taxation of indirect transfers of assets located in the country, pointing out that transfers within
See MoreCosta Rica passes tax reform bill
On 4 December 2018, Costa Rica passed a tax reform bill which includes several tax reform measures. Interest limitation rule: Under the law, an interest limitation rule applies which interest expenses that exceed 20% of the taxpayer's
See MoreBulgaria includes new CFC rule and updates interest limitation rule
On 27 November 2018, Bulgaria published a Bill on amendment and supplement to the Corporate Income Tax Act in the Official Gazette. The Bill includes a new interest limitation and controlled foreign company (CFC) rules in accordance with the EU
See MoreVietnam considering amendments to rules that limit related-party interest deductions
According to recent reports, the Vietnam Ministry of Finance is considering proposed amendments to the country's interest expense deduction restriction. The Decree No. 20/2017/ND-CP, enacted 24 February 2017 (Decree 20), limits deductions
See MoreBulgaria: Parliament approves budget 2019 at first reading
On 7 November 2018, the National Assembly passed the 2019 Budget Act at first reading with 115 MPs in favor and 85 opposed. The budget proposal containing amendments to the corporate tax laws. The proposed corporate income tax amendments are
See MoreArgentina: Taxpayers wait for enactment of draft decree no. 1112/2017
Government has released a draft decree No.1112/2017 for tax reform Law 27430 on December 29, 2017, but it has not officially published yet. This decree includes transfer pricing aspects, permanent establishment (PE) rules, restriction on interest
See MoreAustralia: ATO implements the OECD hybrid mismatch rules
In the 2016–17 Budget, the Australian government announced it would implement the Organisation for Economic Cooperation and Development (OECD) hybrid mismatch and branch mismatch rules from Action Item 2 of the OECD Base Erosion and Profit
See MoreBulgaria: Council of Ministers approves draft Bill for amending income tax
The Council of Ministers approved a draft bill on October 10, 2018 and it have issued by the Finance Minister, Vladislav Goranov, on the Bulgarian Council of Ministers approved the draft bill issued by the Minister of Finance on 30 August 2018. The
See MoreFinland publishes a bill on the new interest deduction limitation rules
On 28 September 2018, the government issued a bill on its final proposal to amend national rules on the deductibility of interest expenses under the EU Anti-Tax Avoidance Directive (2016/1164 / EU). According to proposal, the deductibility of net
See MoreDenmark submits a bill to the parliament to transpose the EU Anti-Tax Avoidance Directives into Danish tax law
On 3 October 2018, the Danish Minister of Taxation submitted a bill to the parliament to transpose the EU Anti-Tax Avoidance Directives (ATAD 1 and ATAD 2) into Danish tax law. The proposals include the extension of the existing hybrid mismatch
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