Portugal: 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
See MoreAustria implements the Mandatory Disclosure Rules
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,
See MoreSlovenia publishes amendments to the CITA in the Official Gazette
On 5 November 2019, the Slovenian government published the amendments to the Corporate Income Tax Act (CITA) in the Official Gazette.
See MoreMexico: Congress approves tax reform package for 2020
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
See MoreIreland: Finance Minister publishes draft law regarding mandatory disclosure rules
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)
See MoreTransfer Pricing Brief: 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
See MoreSpain launches a public consultation on DAC6 reporting requirements
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
See MoreBosnia and Herzegovina signs MLI to implement tax treaty related BEPS measures
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
See MoreDominican Republic: Executive Branch submits 2020 draft budget bill to the National Congress
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
See MoreUS: Treasury department issues regulations removing documentation requirements
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
See MoreCyprus plans to implement EU Directive on mandatory disclosure rules by the end 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
See MoreSlovenia approves amendments to the Corporate Income Tax Act
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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