Estonia implements EU ATAD 2 anti-hybrid measures
On 18 November 2019, Estonian Parliament passed EU Anti-Tax Avoidance Directive (2017/952) (ATAD 2) into Estonian domestic law in its first reading. ATAD 2 follows ATAD 1 in extending the anti-hybrid mismatch provisions on hybrid instruments to
See MoreNigeria: Senate passes third reading of Finance bill 2019
On 21 November 2019, the Senate passed the Finance Bill 2019, which seeks an amendment of Nigeria’s tax laws and make them more responsive to the tax policies of the Federal Government, among other things. The President stated that the amendment
See MoreNigeria: Finance Bill 2019 passes second reading in parliament
On 6 November 2019, the Finance Bill 2019 passed its second reading at the Senate. Main proposed amendments are given below: A lower (i.e. 20%) corporate income tax rate (CIT) applies for companies with turnover between NGN25-million and
See MoreOECD: Input requested for dispute resolution peer reviews
On 18 November 2019 the OECD invited interested parties to submit input in relation to the tenth batch of dispute resolution peer reviews. Information should be submitted to the OECD by 16 December 2019 using the taxpayer input questionnaire. The
See MoreOECD: Global Forum issues reports on tax transparency
On 12 November 2019 the Global Forum on Transparency and Exchange of Information for Tax Purposes issued peer review reports on eight countries. The reports cover Andorra, Curacao, the Dominican Republic, the Marshall Islands, Samoa and the United
See MoreDenmark considers draft Bill to implement DAC6 reporting requirement
On 6 November 2019, the Danish Minister of Taxation published Bill no. L 49 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 MorePoland publishes a law implementing EU directive on dispute resolution and new provisions on APAs
On 14 November 2019, Poland published the Law of 26 October 2019 on resolution of disputes over double taxation and the execution of advance pricing agreements (the “Act”), which generally entered into force on 29 November 2019. The law
See MoreBulgaria: 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
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