Cyprus deposits MLI ratification instrument
The OECD announced that Cyprus deposited its instrument of ratification for the Multilateral Convention to Implement Tax Treaty Related Measures to Prevent Base Erosion and Profit Shifting (MLI) on 23 January 2020. Cyprus also submitted its MLI
See MoreLuxembourg updates list of jurisdictions for exchanging CbC reports
On 27 January 2020, Luxembourg Ministry of Finance published Grand-Ducal Regulation of 24 January 2020 amending Grand-Ducal Regulation of 13 February 2018. The Regulation updates the list of jurisdictions for exchanging Country-by-Country (CbC)
See MorePuerto Rico amends income tax law for deduction of intercompany charges
Recently, Puerto Rico has amended Section 1033.17(a)(17) of the Puerto Rican Internal Revenue Code of 2011 regarding intercompany expense allocation. Previously there was a disallowance of 51% of intercompany charges. According to the amendment,
See MoreGreece: Public Revenue Authority publishes frequently asked question on CbC Report
On 23 January 2020, the Public Revenue Authority released frequently asked question (FAQ) document in English providing the elaborate description of country-by-country (CbC) reporting, including the format of CbC report, local filing obligations,
See MoreBosnia and Herzegovina: Government adopts Law on Profit Tax
On 16 January 2020, Government adopted the amendment in Law on Profit Tax. The Law proposed to exclude leasing companies from the interest deduction limitations provisions. On the other hand, this Law stated that income statements are not necessary
See MoreCzech Republic: Government publishes final draft Bill of DST in Parliament
On 22 January 2020, the final draft Bill regarding the digital service tax (DST) was published in the Parliament. This Bill proposed to introduce a single digital tax of 7% for companies with a global revenue thresholds of EUR 750 million and
See MorePanama introduces CbC registration process via AEOI portal
The FATCA & AEOI Portal of Panama's Directorate General of Revenue (DGI) is now accepting registration for Country-by-Country (CbC) report presentation and notification purposes, as well as for FATCA and CRS purposes. The CbC reporting
See MoreDenmark publishes Law and Executive Order to implement DAC6 reporting requirement
On 27 December 2019 and on 31 December 2019 Denmark published Law and Executive Order, simultaneously, for the implementation of Council Directive (EU) 2018/822 of 25 May 2018 (DAC6) on reportable cross-border tax planning arrangements (DAC6). This
See MoreIceland: MLI enters into force
On 1 January 2020, the Multilateral Convention to Implement Tax Treaty Related Measures to Prevent Base Erosion and Profit Shifting (MLI) entered into force for Iceland. On 26 September 2019, Iceland deposited its instrument of ratification for
See MoreFrance: Finance Minister announces suspension of DST collection for a year
On 22 January 2020, the Finance Minister declared that French government has agreed to suspend collection of its digital services tax (DST) until December 2020.
See MoreFrance and the US agree deal on digital tax
Following talks with the US on taxation of digital companies France has agreed to stop delay collection of its planned digital tax, although the liability for the tax will still accrue. France is planning to impose a 3% digital services tax on
See MoreDominican Republic: DGII issues transfer pricing documentation thresholds for 2020
On January 15, 2020, Directorate General of Internal Revenue (DGII) published the Transfer pricing (TP) reporting threshold for 2020. The related party transaction threshold for transfer pricing reporting purposes in 2020 is DOP11,552,402. The
See MoreCanada: Reminder for the CbC reporting form submission process
On 9 January 2020, Government announced that as from 1st June 2020, Canadian ultimate parent entities that are corporations must file the RC4649 electronically using EFILE or Web Access Code (WAC). It will be available through CRA-T2-certified
See MoreIndia: CBDT issues notification to amend the rules for furnishing master file and CbCR
On 6 January 2020, India’s Central Board of Direct Taxes issued a notification amending the rules for maintenance and furnishing of information and document made by constituent entities of international groups. The amendments mainly clarifies the
See MoreColombia publishes a decree on tax return and TP documentation deadline
On 23 December 2019, Colombian tax authority (DIAN) has published Decree No. 2345 specifying the deadlines for filing and payment of the tax return (declaration) for 2020 and the deadline for transfer pricing (TP) documentation, including
See MoreItaly enacts digital services tax
The Italian Budget Law 2020 introduces a 3% unilateral ‘Digital Services Tax (DST)’ replacing the “Web Tax” and entered into force as of 1 January 2020. The Digital Services Tax (DST) rate is 3% and applies on the revenues from digital
See MoreIreland: President signs Finance Bill 2019 into Law
On 22 December 2019, President, Michael D. Higgins, signed the 2019 Finance bill into law. This Finance Act 2019 implements the taxation changes announced on Budget, including new transfer pricing legislation, introducing some necessary
See MoreMalta implements EU ATAD 2 hybrid mismatch provisions
On 24 December 2019, Malta has published Legal Notice 348 of 2019 implementing EU Anti-Tax Avoidance Directive (2017/952) (ATAD 2) into Malta domestic law. ATAD 2 amends the EU Directive 2016/1164 which applies to mismatches between EU member
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