Bulgaria: Government publishes Law on Amendments to the Corporate Income Tax Act
On 6 December 2019, Law on Amendments to the Corporate Income Tax Act was published in the Official Gazette and it was adopted by the National Assembly on 21st November 2019. Similar amendments in Controlled Foreign Company (CFC) and transfer
See MoreRussia: Tax Dispute Resolution Peer Review
On 28 November 2019 the OECD published a stage 1 peer review report on the Russian Federation’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 MoreGeorgia adopts updated OECD transfer pricing guidelines
On 2 December 2019, the Ministry of Finance issued Decree No. 366 amending the country's transfer pricing legislation. The new decree updates the reference to the 2010 OECD transfer pricing guideline, providing that the 2017 version should
See MoreChina: Tax dispute resolution peer review report
On 28 November 2019 the OECD published a stage 1 peer review report commenting on China’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 MoreBrazil: Tax Dispute Resolution Peer Review Report
On 28 November 2019 the OECD published a stage 1 peer review report on Brazil’s compliance with the minimum standard on tax dispute resolution under Action 14 of the project on base erosion and profit shifting (BEPS). The peer review report
See MoreTransfer Pricing Brief: December 2019
DenmarkDocumentation-Deadlines: On 6 November 2019, the Danish Minister of Taxation published Bill no. L 48 on international taxation. Accordingly, transfer pricing documentation must be submitted to the tax authorities no later than 60 days
See MoreIndia: Parliament passes Taxation Laws (Amendment) Bill, 2019
On 5 December 2019, the upper house of parliament passed the Taxation Laws (Amendment) Bill, 2019. The bill was passed by the Lok Sabha (Lower house) on 2 December 2019. The bill repeals The Taxation Laws (Amendment) Ordinance, 2019. The bill also
See MoreBulgaria legislates amendments to the TP documentation threshold
On 6 December 2019, the Bulgarian Government published the amendments to the Act on Tax and Social Security Procedures in the Official Gazette. According to the amendments, the obligation to prepare such documents from 1 January 2020 will not apply
See MoreOman signs MCAA on automatic exchange of financial information
On 26 November 2019, Oman signed the multilateral competent authority agreement (MCAA) for the automatic exchange of financial account information. The multilateral competent authority agreement (MCAA) provides for the exchange of information under
See MoreUkraine: MLI enters into force
On 1 December 2019, the Multilateral Convention to Implement Tax Treaty Related Measures to Prevent Base Erosion and Profit Shifting (MLI) entered into force with respect to the Ukraine. On 8 August 2019, Ukraine deposited its instrument of
See MoreCanada: BEPS multilateral instrument (MLI) enters into force
On 1 December 2019, the Multilateral Convention to Implement Tax Treaty Related Measures to Prevent Base Erosion and Profit Shifting (MLI) entered into force for Canada. On 29 August 2019, Canada deposited its ratification instrument for
See MoreHigh Court rules that the Danish loss-making company could not deduct royalties paid to its Swiss parent
On 28 October 2019, the Eastern High Court of Denmark published a case (Denmark vs Adecco; Case No SKM2019.537.OLR of 4 July 2019) decision and agreed with the tax authority that a Danish loss-making company could not deduct royalties paid to its
See MoreFinland: Government submits draft proposal on mandatory disclosure rules to parliament
On 31 October 2019, the Finnish Government has submitted a legislative proposal implementing the EU directive on the mandatory disclosure and exchange of cross-border tax arrangements, also known as DAC 6, to the Parliament. Under DAC6, taxpayers
See MoreLithuania proposes amendments to the CITL
On 31 October 2019, the parliament proposed a Bill (No. XIIIP-4116) to amend the Corporate Income Tax Law (CITL). The proposal includes the following measures: The taxable profit of a Lithuanian entities and a Lithuanian permanent
See MoreDenmark publishes the Bill no. L 48 on international taxation
On 6 November 2019, the Danish Minister of Taxation published Bill no. L 48 on international taxation. The bill updated the existing PE (permanent establishment) rules, CFC rules and strengthen the Transfer pricing (TP) rules. PE rules: The
See MoreOman signs MLI to implement tax treaty related BEPS measures
On 26 November 2019, Oman signed the Multilateral Convention to Implement Tax Treaty Related Measures to Prevent Base Erosion and Profit Shifting (MLI). Oman also signed the Multilateral Convention on Mutual Administrative Assistance in Tax
See MoreKenya signs BEPS MLI on multinational group taxation
On 26 November 2019, Kenya signed the Multilateral Convention to Implement Tax Treaty Related Measures to Prevent Base Erosion and Profit Shifting (MLI). The provisional list of reservations and notifications to the MLI (i.e. its MLI position)
See MoreEU tax dispute resolution directive enters into force in Latvian domestic law
On 22 October 2019, the Law of 17 October 2019 on amendments to the Law on Taxes and Duties has been published in the Latvian official gazette, which provides for the implementation of Council Directive (EU) 2017/1852 of 10 October 2017. The
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