Argentina: Tax Authority publishes Law 27541 for implementing tax reform 2020
On 23rd December 2019, Argentina published Law 27541 regarding Social Solidarity and Productive Reactivation in the Official Gazette, which contains measures on corporate income tax, personal income tax, dividend withholding tax etc. The Law was
See MoreGermany gazettes a law implementing EU directive on tax dispute resolution mechanism
On 12 December 2019, the German Official Gazette published a law implementing EU directive on tax dispute resolution providing a uniform mechanism to address tax treaty disputes among EU member states that meets the BEPS Action 14 minimum
See MoreGermany: Federal Ministry of Finance publishes a draft law with significant changes to TP rules
On 10 December 2019, Germany published a draft law implementing EU anti-tax avoidance directive. The Draft Law includes significant changes to the German transfer pricing rules. The following proposed changes have been taken place under the
See MoreFrance: Parliament adopts Finance Bill 2020
On 19 December 2019, The French parliament adopted the Finance Bill for the year 2020 but it is still require to review by the constitutional court. Provisions include in the Finance Bill are given below: Corporate Tax rate The draft Finance
See MoreEstonia: President signs a Law to ratify BEPS MLI
On 13 December 2019, Estonian President has signed a law for ratification of the Multilateral Convention to Implement Tax Treaty Related Measures to Prevent BEPS (MLI). On 4 December 2019, the Parliament ratified the MLI. Estonia must now deposit
See MoreUkraine: SFS explains about foreign exchange differences for transfer pricing purposes
Recently, the Ukraine State Fiscal Service (SFS) has explained about treatment of foreign exchange differences if controlled transactions meet the transfer pricing thresholds. Transactions are classified as controlled transactions if the annual
See MoreSOUTH KOREA: National Assembly approves Multilateral Instrument (MLI)
On 10 December 2019, South Korea's National Assembly has approved multilateral convention to implement tax treaty related measures to prevent Base Erosion and Profit Shifting (MLI). After the ratification process, South Korea will need to deposit
See MoreArgentina: AFIP declares further extensions to TP filing deadlines
On 16 December 2019, the Tax Authority (AFIP) announced further extensions to timeline to transfer pricing (TP) filing returns for the financial years ending on December 31, 2018. Previously, under General Resolution 4538/2019 of 30 July 2019
See MoreIndonesia: Tax dispute resolution peer review report
On 28 November 2019 the OECD published a stage 1 peer review report commenting on Indonesia’s compliance with the minimum standard on tax dispute resolution under Action 14 of the project on base erosion and profit shifting (BEPS). The
See MoreMexico implements economic package 2020
On 9 December 2019, Mexico has published a decree to implement economic package 2020 which was approved by Mexican Congress on 30 October 2019. This Decree will enter into force on January 1, 2020. The economic package consists of the following
See MoreSlovenia publishes guidance on the latest amendments to the CITA
On 2 December 2019, the tax authority has published guidance regarding the latest amendments to the Corporate Income Tax Act (CITA). The guidance also provides for a detailed description about implementation of the hybrid mismatch rules of the EU
See MoreSaudi Arabia introduces E-Service for CbC reporting
Recently, the General Authority of Zakat and Tax (GAZT) of Saudi Arabia have introduced E-Service for country-by-country (CbC) reporting. As per the transfer pricing Bylaws, Saudi Arabian taxpayers that are members of an MNE Group with consolidated
See MoreSerbia: Parliament amends the corporate income tax law including CbCR obligations
On 6 December 2019, the Serbian Parliament passed the legislation that amends the corporate income tax law including requirements for country-by-country (CbC) reporting of controlled transactions within a corporate group. The Law is published in
See MoreTaiwan: MOF announces safe harbor rules for CbC report
On 10 December 2019, the Ministry of Finance (MOF) issued tax ruling no. 10804651540 providing exemption from CbC reporting for Taiwan entities under a MNE Group headquartered outside Taiwan. The safe harbor exemption guidance was issued in late
See MoreSweden publishes draft law to implement DAC6 reporting requirement
On 6 December 2019, the Swedish Ministry of Finance has published draft law on implementation of Council Directive (EU) 2018/822 of 25 May 2018 (DAC6) on reportable cross-border tax planning arrangements (DAC6). This includes measures to require
See MorePeru: SUNAT issues report on interest deduction limitations
On 29 November 2019, the Peruvian Tax Administration (SUNAT) has published Report No. 171-2019-SUNAT/7T0000 on its website regarding exception for the taxpayers engaged in public infrastructure projects, public services and applied research and
See MoreGreece: Parliament adopts tax reform measures
On 6th December 2019, Greek Parliament approved tax reform bill (Law 4646/2019), which contains several measures regarding corporate income tax, personal income tax, withholding tax rates, the participation exemption for capital gains
See MoreNigeria: House of Representatives passes Finance Bill 2019
On 28 November 2019, the House of Representatives passed the Finance Bill 2019. It was passed its third reading by the National Assembly on 21 November 2019. Major proposed amendments are given below: A lower (i.e. 20%) corporate income tax rate
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