Bulgaria: Parliament considers draft Bill to implement DAC6
On 14 November 2019, the National Assembly (NA) accepted for consideration a draft bill to transpose an EU directive on the mandatory automatic exchange of information in relation to reportable cross-border arrangements (DAC6). The NA is currently
See MoreNorway: BEPS multilateral instrument (MLI) enters into force
On 1 November 2019, the Multilateral Convention to Implement Tax Treaty Related Measures to Prevent Base Erosion and Profit Shifting (MLI) entered into force for Norway. On 17 July 2019, Norway deposited its instrument of ratification regarding
See MoreUS: Court of Appeals denies the petition for rehearing of Altera Corp. v. Commissioner
On 12 November 2019, the Ninth Circuit denied the taxpayer’s motion for rehearing en banc through issued an order. The order means that the Ninth Circuit will not reconsider its June 7, 2019 decision upholding the validity of the SBC rule in Reg.
See MoreCyprus amends the company law introducing administrative penalties
On November 1, 2019, the Registrar of Companies published a notice regarding the implementation of Law 149 (1) / 2018 (the Act). The law amends company law and company law regulations with the introduction of administrative penalties on certain
See MoreFinland: Ministry of Finance issues a proposal to implement a corporate exit tax
On 7 November 2019, the Finnish Ministry of Finance published a proposal to introduce a corporate exit tax, largely based on the EU's Anti-Tax Avoidance Directive. The purpose of the EU exit tax is to prevent companies from avoiding tax on gains on
See MoreSouth Africa: SARS publishes list of jurisdiction with effective CbC report exchange agreements
The South African Revenue Service (SARS) published a latest list of jurisdictions. These listed jurisdictions have CbC report exchange agreements with South Africa from 18 October 2019. The list is intended to assist members of the MNE groups
See MoreBulgaria proposes changes to the Corporation Tax Act
On 12 November 2019, a proposal to changes the Corporation Tax Act was submitted to Parliament. The law proposed the following measures: propose to amendments the thin capitalization rules in order to increase the level of expenditure that is
See MoreCzech Republic: Government approves draft bill regarding digital service tax
On 18 November 2019, Government approved a draft bill regarding digital service tax (DST), which responds to the dynamic development of digital economy services and straightens the conditions in the Czech tax environment. The Ministry of Finance
See MoreAustralia extends TP document submission deadline
Significant global entities (SGEs) that have a CbC reporting obligation in Australia for the year ended 31 December 2018 required that their local file (LF), master file (MF), and CbC report are due to be lodged by 31 December
See MoreCosta Rica publishes a resolution outlining guideline on transfer pricing documentation
On 13 November 2019, the Costa Rican tax authority released a Resolution No.DGT-R-49-2019 providing new guidelines on transfer pricing documentation including master file and local file. The new resolution repeal the resolution DGT-R-16-2017
See MoreCroatia: Government publishes transposition Bill regarding DAC6
On 31st October 2019, the Government published a bill regarding the implementation of mandatory disclosure rules pursuant to the EU’s Council Directive 2018/822 of 25 May 2018 (commonly referred to as DAC6) into Croatian’s domestic law. Under
See MorePortugal: Administrative Court issued a decision on Transfer Pricing case
On 10 October 2019, in the case of : n.º 511/2018-T, the Administrative Court issued a decision on the sale of raw materials and goods by a company to related parties. In particular, concerning an undervalued controlled transaction tested using
See MoreSerbia: Parliament adopts draft bill to implement CbC reporting obligations
On 18 October 2019, the Serbian parliament accepted for consideration a bill to implement country-by-country (CbC) reporting obligations for multinational entities (MNEs). Under this ultimate parent entities of an MNE group resident in Serbia are
See MoreGhana: Finance Minister presents 2020 Budget
On 13 November 2019, Finance Minister, Mr. Ken Ofori-Atta, has presented the New Patriotic Party (NPP) government’s fourth Budget Statement and Economic Policy to Parliament which he said is focused on providing liquidity to boost
See MoreKazakhstan: Lower house of parliament approves ratification of BEPS MLI
On 30 October 2019, the lower house of Parliament (Mazhilis) approved the ratification of the Multilateral Agreement on the Implementation of Tax Treaty Related Measures to Prevent Base Erosion and Profit Shifting (MLI). It was approved by the
See MoreBulgaria submits proposal to amends the TP documentation threshold
On 12 November 2019, some of policy makers submitted to Parliament a proposal to amend the rules on thresholds for the Transfer Pricing (TP) documentation rules. It is proposed that the obligation to prepare such documents will not apply to persons
See MoreLatvia deposits its Multilateral Convention ratification instrument
On 29 October 2019, OECD confirmed that Latvia deposited its instrument of ratification for the multilateral convention to implement tax treaty related measures to prevent base erosion and profit shifting (BEPS MLI). The MLI is a multilateral tax
See MoreMalta updates notional interest deduction (NID) guidelines
On 7 November 2019, the Maltese Commissioner for Revenue has updated notional interest deduction (NID) guidelines. The guidelines address a new paragraph regarding attribution of the deemed interest income on alternative bases. The following
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