Transfer Pricing Brief: February 2020
FinlandRequirements-Rule: On 30 December 2019, Finnish President approved the Law 1559/2019 for the implementation of Council Directive (EU) 2018/822 of 25 May 2018 (DAC6) on reporting requirements for cross-border tax planning arrangements.
See MoreEcuador: SRI publishes Resolution regarding temporary corporate income tax
On 29 January 2020, the Internal Revenue Service (SRI) published an Administrative Resolution in the Supplement of the Official Registry 131, which specifies the procedure for filing the tax return and the annual payment of the temporary tax for
See MorePortugal: Draft bill to implement ATAD1 and ATAD2
On 30 January 2020, a draft bill was presented to the Parliament for the execution of the hybrid mismatch rules of the EU Anti-Tax Avoidance Directive and the Directive as amended (ATAD1 and ATAD2). This consists of measures to counter hybrid
See MoreOECD: consultation document on the review of CbC Reporting
On 6 February 2020 the OECD issued a consultation document inviting comments from interested parties on the review of the minimum standard on country by country (CbC) reporting under Action 13 of the project on base erosion and profit shifting
See MorePanama extends CbC reporting deadline and notification again
On 31 January 2020, Directorate General of Revenue of Panama has issued Resolution No. 201-1035 in the official gazette, which extends the deadline for filing the Country by Country Report (CbC) and the Notification as well. The Resolution
See MoreSaudi Arabia deposits MLI ratification instrument
On 23 January 2020, Saudi Arabia has deposited its ratification instrument for the Multilateral Convention to Implement Tax Treaty Related Measures (MLI) to Prevent Base Erosion and Profit Shifting, which was signed on 18 September 2018. Saudi
See MoreCyprus 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
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