Czech Republic releases law Implementing ATAD with others changes
On 27 March 2019, the Czech Republic released the Law of 12 March 2019, which includes the introduction of measures to comply with the EU Anti-Tax Avoidance Directive (ATAD). The law usually enters into force on 1 April 2019. However, the taxation
See MoreFinland: Tax administration publishes guidelines on interest limitation rules
On 7 March 2019, the Finnish tax administration published new guidelines on the rules on interest deduction restrictions, which were amended to comply with EU Anti-Tax Avoidance Directive (ATAD), and contained a general 25% EBITDA interest deduction
See MorePortugal: Parliament proposes to implements The Anti-Tax Avoidance Directive
Recently, the Portuguese Government has submitted to Parliament the Bill No.177/XIII introducing changes to the Income Tax Act to implement certain ATAD-1 rules. The bill proposed rules for the limitation of interest deductions and rules for
See MoreCroatia: Finance Minister declares related party interest rate for 2019
The Croatian Minister of Finance, referring to National Gazette 118/2018 of 27 December 2018, has declared to reduce the interest rate on loans between related parties from 4.55% to 3.96% per annum. The reduction of so called the arm’s length
See MoreBelgium: Parliament approves new restriction on interest deduction
On 31 January 2019, the parliament of Belgium approved legislation implementing the 30% of Earnings before interest, tax, depreciation and amortization (EBITDA) restriction on interest deduction to 1 January 2019. The restriction is according to the
See MoreFrance: Parliament adopts Finance Bill for 2019
On 20 December 2018, the French Parliament approved the Finance Bill for 2019. Tax measures taken under the Finance Bill 2019: The finance bill approves interest deductibility limitation rules in effort to comply with the European Union (EU)
See MoreDenmark: 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 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
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