Portugal publishes changes to various Tax Codes
On 18 September 2019, the Portuguese Government officially published the Law no.119/2019. The new law has changed the following provisions: Corporate income tax: The procedure whereby non-resident companies may waive all or part of the
See MoreNetherlands: Budget proposal for 2020
On 17 September 2019, the Dutch Government published the 2020 budget proposals, which includes the Tax Plan for 2020. The 2020 Tax Plan package consists of the following six bills: the 2020 Tax Plan Bill;the Other 2020 Tax Measures
See MoreRussia: FTS clarifies the application of CUP method
On 2 September 2019, the Federal Tax Service (FTS) of Russia published a Letter No. CA-4-7/17555, about the review of litigation regarding tax control in the field of transfer pricing. For tax purposes, the FTS noted that the courts recognize the
See MoreAustralia updates guideline for simplified transfer pricing record keeping options
On 11 September 2019, the Australian Taxation Office (ATO) released an updated version of Practical Compliance Guideline (PCG) 2017/2 concerning the eligibility criteria for applying simplified transfer pricing record keeping options for
See MoreItaly: New resolution amends patent box regime
The Italian Revenue Agency published Resolution No, 81/E of 9 September 2019 in the official gazette to amend the patent box regime made by Law Decree No. 34 of 30 April 2019, which entered into force on 1 May 2019. The updates
See MoreIndia: CBDT issues Notification on transfer pricing arm’s length tolerance range
On 13 September 2019, the Central Board of Direct Taxes (CBDT) published Notification No. 64/2019, which sets a tolerance range for the variation between the arm’s length price and the transaction price for the 2019-20 assessment year. The
See MoreDenmark: Draft bill on international taxation submits for public comments
On 12 September 2019, the Ministry of Taxes published a major bill on international taxation. The bill will be subjected to a public hearing and subsequently presented to the Danish Parliament. Interested parties can submit their comments by 10
See MoreVietnam clarifies the limitation of the deductibility of loan interest expense for TP purposes
On 11 September 2019, the Department of Taxation of Ha Noi City issued Official Letter No. 71443/CT-TTHT providing clarification on the determination of loan interest costs. Under article 8 (3) of Decree No 20/2017 / ND-CP, the total loan
See MoreCanada deposits ratification instrument for MLI
On 29 August 2019, Canada deposited its ratification instrument for the Multilateral Convention to Implement Tax Treaty Related Measures (MLI) to Prevent Base Erosion and Profit Shifting. The MLI would enter into force on the first day of the
See MoreMexico: Tax reform proposal in economic package 2020
On 8 September 2019, Mexican president Andrés Manuel López Obrador’s presented Economic Package for the fiscal year 2020 to Congress. The economic package proposed following tax reform measures: Transparent Entities International
See MoreUK amends hybrid capital instruments rules
The ‘hybrid capital instruments’ rules are relied upon since 1 January 2019 by many banks and insurers to give corporation tax relief for the coupon payments on regulatory capital securities. These rules have recently been amended by the
See MoreSaudi Arabia: GAZT requests for TP documentation
Recently, the General Authority of Zakat and Tax (GAZT) of Saudi Arabia have requested the taxpayers to submit specific transfer pricing (TP) documentation (master file and local file) in relation to the fiscal year ending 31 December
See MoreRomania introduces mandatory online submission for CbC Reporting
On 19 August 2019, Romania has published Order No. 2.273, amending the rules on submission of Country-by-Country (CbC) reports and notifications, effective from 26 August 2019. Now both CbC reports and notifications must be submitted through
See MoreHong Kong: IRD updates penalty provisions for international tax
On 4 September 2019, the Hong Kong Inland Revenue Department updated its web page on penalty policies related to international tax matters, including fines and criminal penalties, for noncompliance with international tax obligations. The
See MoreRomania implements EU Directive on Dispute Resolution
On 22 August 2019, Romania has published Ordinance No. 19 in the Official Gazette, which implemented the EU Tax Dispute Resolution Directive 2017/1852 in the tax procedure code (Law no. 207/2016). The provisions apply to complaints submitted
See MoreRussia reduces the Interest rate from September 2019
On 6 September 2019, the Russian Central Bank announced the decision to reduce the key rate from 7.25% to 7.00% with effect from 9 September 2019. For tax purposes, the key rate is important in relation to the safe harbor rates for interest
See MoreFrance: Tax Authority issues a Ruling on interest deduction
The tax authority issued a ruling regarding the deductibility of interest paid to a related Belgian company benefiting from the notional interest regime. On 4 September 2019, the French General Directorate of Public Finance clarified that tax
See MoreTransfer Pricing Brief: September 2019
AustraliaFinancial services: On 28 August 2019, the Australian Taxation Office (ATO) published draft Practical Compliance Guideline PCG 2019/D3, which sets out the proposed compliance approach for the use of the arm’s-length debt test (ALDT)
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