Austria implements the Mandatory Disclosure Rules

08 November, 2019

On 22 October 2019, the government of Austria officially published the EU-Mandatory Disclosure Act implementing the European Union (EU) Directive on the mandatory disclosure and exchange of cross-border tax arrangements (DAC6). Under DAC6,

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Slovenia publishes amendments to the CITA in the Official Gazette

08 November, 2019

On 5 November 2019, the Slovenian government published the amendments to the Corporate Income Tax Act (CITA) in the Official Gazette.

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Mexico: Congress approves tax reform package for 2020

07 November, 2019

On 30 October 2019, Mexico’s Congress has approved the tax reform for 2020 which was presented by President Andrés Manuel López Obrador’s on September 8, 2019. The Reform incorporates fundamentals of the Base Erosion and Profit Shifting

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Ireland: Finance Minister publishes draft law regarding mandatory disclosure rules

07 November, 2019

On 17 October 2019, the Finance Minister published draft legislation as part of Finance Bill 2019 for the implementation of European Union (EU) Directive 2018/822 regarding mandatory disclosure and exchange of cross-border tax arrangements (DAC6)

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Transfer Pricing Brief: November 2019

06 November, 2019

SloveniaMain corporate income tax rate: Slovenia increased the corporate income tax rate from 19% to 20% with minimum tax rate 7% under the amendments of corporate income tax act. Special rules for hybrid instruments or entities: Slovenian

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Spain launches a public consultation on DAC6 reporting requirements

06 November, 2019

On 21 October 2019, the Spanish Ministry of Finance has launched a public consultation on the draft regulation approving the model forms to be used in the context of the implementation of Council Directive (EU) 2018/822 of 25 May 2018 (DAC6) on

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Bosnia and Herzegovina signs MLI to implement tax treaty related BEPS measures

05 November, 2019

On 30 October 2019, Bosnia and Herzegovina signed the Multilateral Convention to Implement Tax Treaty Related Measures to Prevent BEPS (MLI). The countries involved in the Inclusive Framework are working towards implementation of the BEPS

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Dominican Republic: Executive Branch submits 2020 draft budget bill to the National Congress

04 November, 2019

On 1st October 2019, the Executive Branch sent 2020 draft budget bill to the National Congress the 2020 draft budget bill for its knowledge, discussion and approval. The bill proposes measures to extend the rules on interest deduction and

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US: Treasury department issues regulations removing documentation requirements

03 November, 2019

On 31 October 2019, the US treasury department issued final regulations (TD 9880), repealing section 385, which sets out minimum documentation requirements that must normally be met in order for certain related-party interests in a corporation to

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Cyprus plans to implement EU Directive on mandatory disclosure rules by the end 2019

03 November, 2019

On 16 September 2019, the Cyprus Tax Department announced that the legislation implementing the EU Directive 2018/822 on mandatory disclosure requirements will be introduced before the end of 2019. The announcement confirmed that, for arrangements

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Slovenia approves amendments to the Corporate Income Tax Act

31 October, 2019

On 23 October 2019, the Slovenian government adopted amendments to the Corporate Income Tax Act. The amendments are following: The Corporate income tax is increased from 19% to 20%;A minimum corporate tax at a rate of 7% is introduced which

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Cyprus launches a public consultation regarding DAC6 to transpose into local law

31 October, 2019

On 22 October 2019, the Cypriot tax authorities launched a public consultation on draft legislation to implement DAC6 into local Cypriot law. The consultation is due to run until November 12, 2019. The draft legislation will then be subject to the

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Turkey: Government submits draft law on tax regulation to the Parliament

30 October, 2019

On 24 October 2019, the Turkish Government submitted a new draft law to the Parliament, which proposes regulations on the tax system. The draft law introduces new taxes, namely digital services tax (DST), valuable house tax and accommodation tax.

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US: Tax Court issues an opinion in the case of Eaton Corp. v. Commissioner regarding APA

29 October, 2019

On 28 October 2019, the U.S. Tax Court published an order in the case of Eaton Corp. v. Commissioner related to advance pricing agreements (APAs). In that case, Eaton Corporation (P-Petitioner) and Commissioner of Internal Revenue

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Turkey: Revenue Administration issues guideline on MAP

28 October, 2019

On 17 October 2019, the Turkish Revenue Administration has released guideline on the mutual agreement procedure (MAP) under double taxation agreement on their website as well as a table of guidance indicating the time limits for each country

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Italy publishes Law 117 to implement EU Directives

28 October, 2019

On 4 October 2019, Italy has published Law No. 117 in the Official Gazette, approving the legislative decrees for the implementation of several EU Directives. The Directives will be consulted on by parliament but do not require further approval

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Greece: AADE publishes Circular E. 2183 of 10 October 2019 on limitation of interest payments

27 October, 2019

On 10 October 2019, the Greek Revenue Authority (AADE) published Circular E. 2183 of 10 October 2019 on the deductibility of interest payments that have been grossed-up to include the tax amount. The circular describes that the tax paid is

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Germany publishes updated draft bill on DAC 6 Rules

27 October, 2019

On 9 October 2019, the German Federal Government issued an update of the draft legislation on Mandatory Disclosure Rules addressing the implementation of the European Union (EU) Directive on the mandatory disclosure and exchange of cross-border tax

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