SOUTH KOREA: National Assembly approves Multilateral Instrument (MLI)
On 10 December 2019, South Korea's National Assembly has approved multilateral convention to implement tax treaty related measures to prevent Base Erosion and Profit Shifting (MLI). After the ratification process, South Korea will need to deposit
See MoreArgentina: AFIP declares further extensions to TP filing deadlines
On 16 December 2019, the Tax Authority (AFIP) announced further extensions to timeline to transfer pricing (TP) filing returns for the financial years ending on December 31, 2018. Previously, under General Resolution 4538/2019 of 30 July 2019
See MoreIndonesia: Tax dispute resolution peer review report
On 28 November 2019 the OECD published a stage 1 peer review report commenting on Indonesia’s compliance with the minimum standard on tax dispute resolution under Action 14 of the project on base erosion and profit shifting (BEPS). The
See MoreMexico implements economic package 2020
On 9 December 2019, Mexico has published a decree to implement economic package 2020 which was approved by Mexican Congress on 30 October 2019. This Decree will enter into force on January 1, 2020. The economic package consists of the following
See MoreSlovenia publishes guidance on the latest amendments to the CITA
On 2 December 2019, the tax authority has published guidance regarding the latest amendments to the Corporate Income Tax Act (CITA). The guidance also provides for a detailed description about implementation of the hybrid mismatch rules of the EU
See MoreSaudi Arabia introduces E-Service for CbC reporting
Recently, the General Authority of Zakat and Tax (GAZT) of Saudi Arabia have introduced E-Service for country-by-country (CbC) reporting. As per the transfer pricing Bylaws, Saudi Arabian taxpayers that are members of an MNE Group with consolidated
See MoreSerbia: Parliament amends the corporate income tax law including CbCR obligations
On 6 December 2019, the Serbian Parliament passed the legislation that amends the corporate income tax law including requirements for country-by-country (CbC) reporting of controlled transactions within a corporate group. The Law is published in
See MoreTaiwan: MOF announces safe harbor rules for CbC report
On 10 December 2019, the Ministry of Finance (MOF) issued tax ruling no. 10804651540 providing exemption from CbC reporting for Taiwan entities under a MNE Group headquartered outside Taiwan. The safe harbor exemption guidance was issued in late
See MoreSweden publishes draft law to implement DAC6 reporting requirement
On 6 December 2019, the Swedish Ministry of Finance has published draft law 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 MorePeru: SUNAT issues report on interest deduction limitations
On 29 November 2019, the Peruvian Tax Administration (SUNAT) has published Report No. 171-2019-SUNAT/7T0000 on its website regarding exception for the taxpayers engaged in public infrastructure projects, public services and applied research and
See MoreGreece: Parliament adopts tax reform measures
On 6th December 2019, Greek Parliament approved tax reform bill (Law 4646/2019), which contains several measures regarding corporate income tax, personal income tax, withholding tax rates, the participation exemption for capital gains
See MoreNigeria: House of Representatives passes Finance Bill 2019
On 28 November 2019, the House of Representatives passed the Finance Bill 2019. It was passed its third reading by the National Assembly on 21 November 2019. Major proposed amendments are given below: A lower (i.e. 20%) corporate income tax rate
See MoreBulgaria: Government publishes Law on Amendments to the Corporate Income Tax Act
On 6 December 2019, Law on Amendments to the Corporate Income Tax Act was published in the Official Gazette and it was adopted by the National Assembly on 21st November 2019. Similar amendments in Controlled Foreign Company (CFC) and transfer
See MoreRussia: Tax Dispute Resolution Peer Review
On 28 November 2019 the OECD published a stage 1 peer review report on the Russian Federation’s compliance with the minimum standard on tax dispute resolution under Action 14 of the project on base erosion and profit shifting (BEPS). The
See MoreGeorgia adopts updated OECD transfer pricing guidelines
On 2 December 2019, the Ministry of Finance issued Decree No. 366 amending the country's transfer pricing legislation. The new decree updates the reference to the 2010 OECD transfer pricing guideline, providing that the 2017 version should
See MoreChina: Tax dispute resolution peer review report
On 28 November 2019 the OECD published a stage 1 peer review report commenting on China’s compliance with the minimum standard on tax dispute resolution under Action 14 of the project on base erosion and profit shifting (BEPS). The
See MoreBrazil: Tax Dispute Resolution Peer Review Report
On 28 November 2019 the OECD published a stage 1 peer review report on Brazil’s compliance with the minimum standard on tax dispute resolution under Action 14 of the project on base erosion and profit shifting (BEPS). The peer review report
See MoreTransfer Pricing Brief: December 2019
DenmarkDocumentation-Deadlines: On 6 November 2019, the Danish Minister of Taxation published Bill no. L 48 on international taxation. Accordingly, transfer pricing documentation must be submitted to the tax authorities no later than 60 days
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