Czech 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 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 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 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 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
See MoreAustralia issues final PCG and ruling on hybrid mismatch rules
The Australian Taxation Office has issued Practical Compliance Guideline (PCG) 2019/6 and Law Companion Ruling (LCR) 2019/3, related to the concept of structure arrangements in relation to Australia's new hybrid mismatch rules.
See MoreHungary: Parliament approves exit tax and hybrid mismatch rule in line with ATAD
On 12 July 2019, the Hungarian legislator passed an anti-tax avoidance rule for the implementation exit tax and hybrid mismatch rules in line with the EU Anti-Tax Avoidance Directive (ATAD). The exit tax rules would apply from 1 January 2020
See MoreNetherlands: Cabinet submits new bill against tax avoidance
The Dutch government published a legislative proposal engaging rules to counter hybrid mismatches into the Dutch corporate income tax act pursuant to the EU Anti-Tax Avoidance Directive as agreed upon in May 2017 (ATAD2). ATAD2 would address tax
See MoreNew Zealand: Inland Revenue publishes revised transfer pricing regime
On 29 April 2019, Inland Revenue published the final versions of the special reports on the new rules for base erosion and profit shifting (BEPS). The rules were enacted in the Taxation (Neutralising Base Erosion and Profit Shifting) Act 2018 on 27
See MoreCzech 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 MoreSweden: Proposal for the extension of the hybrid match rules submits for comments
On 1 February 2019, the Ministry of Finance has sent a memorandum on referral with a proposal to extend the so-called hybrid rules. The purpose of the rules is to prevent differences in countries legislation being used in cross-border arrangements
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 More