Germany: Federal Tax Court changes perspective on domestic TP adjustments in tax treaty cases
On 27 February 2019, three recently published decisions (IR 51/17, IR / 73/16, and IR 81/17) provided that the German Federal Tax Court (BFH) had changed its opinion on the application of transfer pricing (TP) rules in relation to transfer
See MoreFrance: Government publishes transposition order of DAC6
On October 22, 2019, Government published a French Ordinance No. 2019-1068 of 21 October 2019, regarding the Automatic and Compulsory Exchange of Information in the Field of Taxation in Relation to Cross-Border Devices for Reporting. The EU
See MoreCzech Republic: Parliament debates proposed changes to Income Taxes Act
The Chamber of Deputies debate with some changes to the Income Taxes Act, which may come into force in 2020. The measures must be approved by the Chamber and the Senate and signed by the president before coming into force. The provisions of the
See MoreNorway proposes to amends interest deduction limitation rules and R&D incentive scheme
On 7 October 2019, the Ministry of Finance presented its budget proposal for fiscal year 2020. The budget proposed to amends the interest expense deduction limitation rules and the Norwegian research and development (R&D) incentive scheme.
See MoreColombia: Government submits tax reform bill to Congress after court ruling
On 22 October 2019, the Colombian Government submitted a new tax reform bill to Congress that will replace tax reform bill 2019 (Law No. 1943 of 2018). The tax reform bill 2019, which came into force on 1 January 2019, is invalid due to procedural
See MoreIreland: Finance Minister announces Finance bill for the year 2020
On 16 October 2019, the Finance Minister, Paschal Donohoe TD, announced Cabinet approval for the publication of the Finance Bill 2019. It was published on 17 October 2019. The Bill sets out the legislative provisions to bring effect to the tax
See MoreBulgaria: Draft Law on implementation of hybrid mismatch and exit tax measures submits to NA
On 9 October 2019, a draft Law on “Amendment and Supplementation of the Corporate Income Tax Act” was presented to the National Assembly (NA). The bill proposes provisions transposing the exit taxation measures of the EU Anti-Tax Avoidance
See MoreIreland: Tax authority publishes a manual on MLI Tie-Breaker Rule
On October 9, 2019, the tax authorities published a guide that describes the way of how the new rule regarding the determination of treaty residence of dual-resident companies applies under the Multilateral Convention to Implement Tax Treaty
See MoreSlovak Republic: Implementing mandatory disclosure rules
On 14 October 2019, the Government of Slovak Republic published in the Collection of Laws the final legislation that transposes the Directive on Administrative Cooperation in Taxation (DAC6) commencing Mandatory Disclosure Rules (MDR). On
See MoreCyprus: Tax department publishes income tax return form for 2018
On 3 October 2019, the Cyprus tax department has published corporate income tax return form (TD4) for 2018. The basic difference between 2018 and 2017 return form is the part 3. Under this taxpayer is requested to confirm whether a Transfer Pricing
See MoreRussia: MLI enters into force
On 1 October 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 Russian Federation. On 18 June 2019 the Russian Federation deposited
See MoreRussia enacts legislative changes on Transfer Pricing and MAP
On 29 September 2019, the Russian Government signed a Law no. 325-FZ (Amendments to the Tax Code of the Russian Federation) and published in the Official Gazette. The main amendments relating to transfer pricing are as
See MoreBelgium approves draft law to transpose EU directive on cross-border arrangements
On 11 October 2019, the Belgian Council of Ministers approved a draft law to transpose EU Directive 2018-822 of 25 May 2018 on reportable cross-border tax planning arrangements. The Directive includes measures to require the reporting of
See MoreIndia: CBDT amends rules to calculate interest income relating to Secondary Adjustments
On 30 September 2019, the Central Board of Direct Taxes (CBDT) has amended rule 10CB which provide for computation of interest income relating to secondary adjustments. The changes remove anomalies and clarify the compliance and computational
See MoreIreland: Govt. announces draft budget 2020
On 8 October 2019, Govt. announced draft Budget 2020. This draft Budget introduced some amendments in respect of corporate income tax, transfer pricing, dividend withholding tax, personal income tax, small and medium enterprises (SMEs),
See MoreBrazil: Federal Revenue approves Private Ruling 276/2019
On 2 October 2019, the Brazilian tax authorities released a private ruling PLR 276/2019 on tax treatment of cross-border cost sharing arrangements. The ruling provides a consultation solution that was requested by an entity whose direct parent
See MoreZambia presents the budget for 2020
On 27 September 2019, the Minister of Finance (MOF) presented the budget for 2020 to the National Assembly. Under the budget the following important amendments to the Income Tax Act will take effect from 1 January 2020: Corporate tax
See MorePeru: SUNAT publishes resolution on submission of CbC reports
On 29 September 2019, the Peruvian Tax Administration (SUNAT) has published Resolution No. 188-2019/SUNAT in the Official Gazette, through which the comprehensive system for the reception and automatic exchange of information (IR AEOI system) was
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