Cyprus launches a public consultation regarding DAC6 to transpose into local law
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
See MoreTurkey: Government submits draft law on tax regulation to the Parliament
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.
See MoreUS: Tax Court issues an opinion in the case of Eaton Corp. v. Commissioner regarding APA
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
See MoreTurkey: Revenue Administration issues guideline on MAP
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
See MoreItaly publishes Law 117 to implement EU Directives
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
See MoreGreece: AADE publishes Circular E. 2183 of 10 October 2019 on limitation of interest payments
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
See MoreGermany publishes updated draft bill on DAC 6 Rules
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
See MoreGermany: 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
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