Nigeria: FIRS issues Income Tax (CRS) Regulations, 2019
Recently, the Federal Inland Revenue Service (FIRS) issued the Income Tax (Common Reporting Standard (CRS)) Regulations, 2019. The effective date of the regulations is 1 July 2019. This follows Nigeria's signing of the Multilateral Convention on
See MoreUkraine: MOF amends taxpayer’s audit compliance with the arm’s length principle
On 6 September 2019, the Ukrainian Ministry of Finance (MOF) has published Order No. 307 of 16 July 2019 in the official gazette amending Order No. 399 of 30 March 2017. The amendment clarifies the procedures to audit compliance with the arm’s
See MorePortugal legislates EU Directive on Dispute Resolution
On 19 September 2019, the Portuguese Official Gazette published a Law no. 120/2019, the new law establishes dispute settlement mechanisms involving the competent authorities of Portugal and other Member States of the European Union as a result of
See MorePhilippines: BIR issues guidelines for transfer pricing audits
The Bureau of Internal Revenue (BIR) has issued Transfer Pricing Audit Guidelines under Revenue Audit Memorandum Order (RAMO) No. 1-2019 on 20 August 2019, which provides standardized audit procedures and techniques in auditing taxpayers with
See MoreIndia cuts corporate tax rate for domestic companies
On 20 September 2019, the Government of India introduced the Taxation Laws (Amendment) Ordinance, 2019. According to the Ordinance, the government makes certain changes to the Income Tax Act of 1961 and the Finance Act (No 2) of 2019. The main
See MoreGreece: Prime Minister announces tax cuts and promised reform
On 12 September 2019, the Prime Minister has made an announcement of their confirmation to introduce tax rate cuts and other planned tax measures at the opening of the annual International Trade Fair of Thessaloniki. According to plan, corporate
See MoreUruguay ratifies BEPS multilateral instrument
On 18 September 2019, Mr. Tabaré Vázquez, the president of Uruguay signed the law for the ratification of the multilateral convention to implement Double Taxation Agreement (DTA) related measures to prevent Base Erosion and Profit Shifting
See MorePortugal 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
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