Colombia: DIAN issues resolution on MAP
On 13 August 2019, the Colombian National Tax Authority (Dirección de Impuestos y Aduanas Nacionales, DIAN) has published Resolution No. 000053 in the official gazette which establishes Mutual Agreement Procedure (MAP) to avoid double taxation and
See MoreSlovenia implements the mandatory disclosure rules
On 28 May 2019, the Slovenian Parliament has approved the EU Directive on the mandatory disclosure and exchange of cross-border tax arrangements (DAC6). The final Slovenian Mandatory Disclosure Rules legislation is significantly aligned to the
See MorePoland: Ministry of Finance publishes a draft bill to implement EU ATAD 2 anti-hybrid measures
On 23 August 2019, the Poland Ministry of Finance released a draft bill outlining several provisions to implement EU ATAD 2 anti-hybrid measures. The main purpose of implementing the anti-hybrid measures is to counteract the situation of double
See MoreUS: Court of Appeals approves Tax Court’s decision in Transfer Pricing case
On 16 August 2019, the U.S. Court of Appeals for the Ninth Circuit in the case of: Amazon.com, Inc. v. Commissioner, 148 T.C. 108 (2017) issued a decision in favor of Amazon concerning the regulatory definition of intangible assets and the
See MoreAustralia: ATO compliance approach to the arm’s length debt test
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) for the purposes of
See MoreUkraine issues guidance on transactions between non-resident and its representative offices
On 16 August 2019, the Ministry of Finance issued Order No. 345 providing guidelines on transfer pricing arrangements for transactions between non-residents and their representative offices and permanent establishments in Ukraine. The Order
See MoreItaly updates CbC reporting requirements
On 8 August 2019, Italy has published the Ministerial Decree in the Official Gazette amending the Ministerial Decree of 23 February 2017 regarding Country-by-Country reporting (CbCR). The Decree amends Article no. 7 on the use of CbC
See MoreIsrael publishes transfer pricing form for 2019
The tax administration of Israel updated transfer pricing declaration Form-1385, which is a declaration by entities regarding their intercompany transactions with related parties. The tax administration of Israel recently announced that the use
See MoreDenmark: Tax Agency allows for the opportunity to re-open certain transfer pricing cases
On 12 July 2019 the Danish Tax Agency issued a new decree (SKM2019.374.SKTtST) regarding transfer pricing documentation in response to the Supreme Court’s decision in the Microsoft case. The decree allows some taxpayers to reopen Denmark transfer
See MoreUS: IRS withdraws “Altera Memo” directive on cost-sharing arrangements
On 5 August 2019, the U.S. IRS published a memorandum dated 31 July 2019 on the formal withdraw of Directive LB&I-04-0118-005. Directive LB&I-04-0118-005 was issued on 12 January 2018 and provided instructions for examiners on transfer
See MoreLithuania further changes TP documentation rules
On 12 August 2019, the tax authorities released the new transfer pricing (TP) rules, which will apply from 2019, in addition to the previously announced new TP rules. The tax authorities also include the following TP measures: Abolishing the
See MorePhilippines: House Committee approves bill on corporate income tax reform
The House Committee on Ways and Means has approved the administration’s second tax reform package (Corporate Income Tax and Incentives Reform Act (CITIRA)) on 14 August 2019, which aims to reduce corporate income taxes (CIT) and rationalize
See MoreLuxembourg: Government submits EU Anti-Tax Avoidance Directive to Parliament
On 9 August 2019, Luxembourg Government submits draft law to the Parliament for the execution of the expanded hybrid mismatch rules of the European Union (EU) Anti-tax Avoidance Directive as amended (ATAD2). The draft law aims at broadening the
See MoreBulgaria publishes new mandatory TP documentation requirements
On 13 August 2019, amendments to the Tax and Social Security Procedure Code (TSSPC) were published in the State Gazette. The law introduced the mandatory new transfer pricing (TP) documentation requirements in Bulgaria. Documentation
See MoreArgentina: Tax authorities declares extensions to TP filing deadlines
Tax Authorities has issued General Resolution 4538/2019 of 30 July 2019 and published in the Official Gazette on July 31, 2019. It entered into force from July 31, 2019. This resolution made an extension to timeline to transfer pricing filing
See MoreHungary publishes legislation implementing EU directive on hybrid mismatch rules
On 23 July 2019, Hungary published a legislation through an official gazette that provides for the implementation of exit tax and hybrid mismatch rules of the EU Anti-Tax Avoidance Directive (ATAD). On 12 July 2019, the Hungarian legislator passed
See MoreNorway deposits ratification instrument for MLI
On 17 July 2019, Norway deposited its instrument of ratification for the multilateral convention to implement tax treaty related measures to prevent base erosion and profit shifting (MLI). The MLI will enter into force on 1 November 2019 for
See MoreBelgium: CbC report corrections guidelines
On 30 July 2019, the Federal Public Service Finance of Belgium issued a notice on its transfer pricing - BEPS 13 guidance page that the MyMinfin Portal is now available for the submission of Country-by-Country (CbC) report
See More