Transfer Pricing Brief: January 2020
BrazilDispute resolution-Best practices: The OECD peer review report regarding Brazil published on 28 November 2019 notes that Brazil has concluded 35 double tax treaties all of which contain a provision relating to the mutual agreement
See MoreGermany publishes draft bill to implements ATAD hybrid mismatch rules
On 10 December 2019, the German Ministry of Finance issued a draft bill to implement the anti-tax avoidance directive (ATAD) including Hybrid mismatch rules. The hybrid mismatch rules will apply from 1 January 2020 to address double deduction
See MoreGermany gazettes a law implementing EU directive on cross-border tax planning arrangements
On 30 December 2019, the German Official Gazette published a law implementing EU directive on reporting requirements for cross-border tax planning arrangements. The directive commonly referred to as DAC 6 which require the taxpayers and
See MoreEcuador: Government publishes tax reform for 2020
On 31 December 2019, the Government published tax reform 2020 through Law of Simplicity and Tax Progressivity (Law No. SAN-2019-1270) in the Official Gazette. The Law effects from 1 January 2020. Some of the key provisions are given
See MoreFinland: President sign the law to implement the EU directive on hybrid mismatch rules
On 30 December 2019, the President of Finland signed the Law 1567/2019 that provides for the implementation of the hybrid mismatch rules of the Anti-Tax Avoidance Directive, as amended by Council Directive (EU) 2017/952 (ATAD2). The hybrid
See MoreMalta publishes Regulation to implement DAC6 reporting requirements
On 17 December 2019, Malta published Cooperation with Other Jurisdictions on Tax Matters (Amendment) Regulations 2019 through Legal Notice 342 of 2019. The Amendments transpose the provisions of Council Directive 2018/822 of 25 May 2018 amending
See MoreDenmark: 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 Denmark. On 30 September 2019, Denmark deposited its instrument of ratification for the
See MoreFinland adopts EU directive on cross-border tax planning arrangements
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. Under DAC6, taxpayers
See MoreHong Kong: IRD extends CbC reporting deadline for local filing
On 18 December 2019, Inland Revenue Department announced an extension to the due date for local filing of some country-by-country tax reports. The local filing requirement applies to a relevant accounting period beginning on or after 1 January
See MoreDTA between Ecuador and Japan enters into force
On 28 December 2019, the Double Taxation Agreement (DTA) between Ecuador and Japan was entered into force and applies from 1 January 2020. The DTA contains Dividends rate 5%, Interest rate 10%, and Royalties rate
See MoreKazakhstan: State Revenue Committee clarifies statute of limitation for tax violations
Recently, the State Revenue Committee (SRC) described that the statute of limitations period in case of tax violations is 3 years instead of 5 years as from 1 January 2020. Before 1st January 2020, however, the statute of limitation period remains
See MorePanama extends CbC reporting deadline and notification
On 27 December 2019, Directorate General of Revenue of Panama has issued Resolution No. 201-9116 and 201-9117, with effect from the date of publication. Resolution No. 201-9116 extends the filing of Country by Country (CbC) reporting until 31
See MoreMalaysia: IRB releases Transfer Pricing audit framework for 2019
On 15 December 2019, the Malaysian Inland Revenue Board (“MIRB”) published the TP audit framework (2019). The Transfer Pricing Audit Framework 2019 is effective from 15 December 2019 and replaces the Transfer Pricing Audit Framework 2013 which
See MoreLuxembourg implements EU ATAD 2 anti-hybrid measures
On 19 December 2019, the Luxembourg Parliament approved draft law implementing EU Anti-Tax Avoidance Directive (2017/952) (ATAD 2) into Luxembourg domestic law. ATAD 2 amends the EU Directive 2016/1164 which applies to mismatches between EU member
See MoreVietnam: MOF publishes draft Decree on deductible interest expenses
On 12 December 2019, the Vietnam Ministry of Finance (MOF) has published the draft Decree amending and supplementing Clause 3, Article 8 of Decree 20/2017/ND-CP to regulated approach on determining the deductibility for interest expense for
See MoreQatar publishes new regulations to amend income tax law
On 11 December 2019, Qatar published Executive regulations 39/2019 in the Official Gazette, introduced new Income Tax Law No. 24 of 2018. The new regulations are generally effective from 12 December 2019. Key features of the new regulations
See MoreOECD: Peer review reports on exchange of information on tax rulings
On 23 December 2019 the OECD released the 2018 peer review reports on the exchange of information on tax rulings. The reports cover implementation of the minimum standard under action 5 of the OECD action plan on base erosion and profit shifting
See MoreCosta Rica: Ministry of Finance publishes draft resolution on APA guidelines
In December 2019, the Costa Rican Ministry of Finance released a draft resolution regarding the procedures for processing advance pricing agreements (APAs). The draft guidelines state that APA applications would need to be addressed to the
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