Poland: Ministry of Finance declares key changes under 2019 tax reform
Poland’s Ministry of Finance announced, significant changes in the tax law are planned in Poland as of 2019. The Ministry announced the following key measures, among others: Stricter conditions for the application of withholding tax exemption
See MoreAustralia: Parliament adopts hybrid mismatch legislation
On 16 August 2018, Treasury Laws Amendment (Tax Integrity and Other Measures No. 2) Bill 2018 containing the hybrid mismatch integrity measures was passed by the Parliament. The bill includes the measures to prevent entities that are liable to
See MoreMalta updates guidelines on the application of the notional interest deduction (NID) rules
On 8 August 2018, the Maltese Commissioner for Revenue published update guidelines on the application of the notional interest deduction (NID) rules. Under the NID, a Malta company or partnership, including a Malta permanent establishment of a
See MoreFinland: Ministry of Finance officially submits its budget proposal for the year 2019
On 9 August 2018, the Ministry of Finance officially submitted its budget proposal for next year 2019. The budget introduced changes to the CFC definition and applicable exemptions, including reducing the control threshold for a company that
See MoreAustralia: Improving the integrity of the thin capitalization rules
The Australian Government announced that it will implement two changes to improve the integrity of Australia’s thin capitalization rules in the 2018-19 Budget. The changes are: requiring entities to align the value of their assets for thin
See MorePoland releases draft law amending transfer pricing rules
On 16th July 2018, Poland has released a bill to amend the country's transfer pricing rules in line with the results of the BEPS project and the OECD transfer pricing guidelines 2017 in order to improve the taxation of large multinational companies.
See MoreFrance publishes arm’s length interest rate for third quarter of fiscal year 2018
The arm’s length interest rates used in determining the deductibility of interest payments to shareholders for companies whose fiscal year ends between 30 June 2018 and 29 September 2018 has been published by France. The portion of interest
See MoreIreland publishes tax and duty manual on loans applied in acquiring an interest in a company
On 16 July 2018, Irish revenue authority published a Tax and Duty Manual concerning loans applied in acquiring an interest in a company. The contents of Tax and Duty Manual Part 08-05-02 - Loans applied in acquiring an interest
See MoreLuxembourg: Cabinet approves draft law for implementation of EU anti-tax avoidance directive
On 15 June 2018, the Luxembourg Cabinet approved a draft bill providing for measures to implement the EU Anti-Tax Avoidance Directive (ATAD). The draft bill includes the new provisions on the limitation of interest deduction, which limit the
See MoreAustralia: Draft PCG for Restructures of Hybrid Mismatch Arrangements
As part of the 2016-17 Federal Budget, the Australian government announced it would implement the Organisation for Economic Co-operation and Development's (OECD) Hybrid Mismatch rules developed under Action Item 2 of the OECD Base Erosion and Profit
See MoreAustralia updates international dealings schedule for 2018 tax year
The Australian Taxation Office (ATO) has released the 2018 International dealings schedule (IDS) and their instructions for 2018 tax years. The IDS must be lodged by businesses that provide a response at the trigger questions of the relevant
See MoreJersey: Ministry of Treasury presents 2018 Budget to the States Assembly
The Minister for Treasury and Resources, Alan Maclean, has presented the Finance Budget Law 2018 and it will be effective from May 4, 2018. The Government had published the Draft Budget 2018 on October 3, 2017. The measures generally applicable as
See MoreUS: IRS issues guidance on restriction on interest deduction
On 2 April 2018, the Treasury Department and the Internal Revenue Service (IRS) published Notice 2018-28, which provides guidance for computing the business interest expense limitation under recent tax legislation enacted on Dec. 22, 2017. In
See MoreAustralia: Minimum interest rate for simplified transfer pricing record keeping for 2018
The Australian Taxation Office (ATO) has updated its guidance on simplified transfer pricing record keeping options to include the minimum interest rate for the simplified option for low-level outbound loans for the 2018 income year, which is set at
See MoreKorea: Imposed limitation on expense deductions relating to hybrid financial instruments
The 2018 Tax Reform introduces a limitation on deductible expenses relating to hybrid mismatch arrangements as a commitment to implement the hybrid mismatch rules recommended by the Organisation for Economic Co-operation and Development’s. The
See MoreSerbia: Ministry of Finance updates rulebook on arm’s length interest rates for 2018
The Serbian Ministry of Finance has updated the rulebook concerning arm’s length interest rates. The Rulebook was published in the Official Gazette of Serbia No. 18/2018 dated 9 March 2018. The Rulebook contains the prescribed interest rates
See MoreAustralia: Implementing the OECD Hybrid Mismatch Rules
The Australian Government announced in the 2016-17 and 2017-18 Budgets that it would implement the Organisation for Economic Co operation and Development’s (OECD) rules aimed at eliminating double non-taxation benefits from hybrid mismatch
See MoreNetherlands: Dutch Council of Ministers approves fiscal policy agenda
The Council of Ministers approved the fiscal policy agenda on a package to combat tax avoidance and tax evasion. The most important changes are summarized below: Corporate Income Tax (CIT) rate: According to the Agenda, the current standard Dutch
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