Bulgaria approves CbC Exchange Agreements with U.S.
On 10 July 2019, Bulgaria's Council of Ministers approved two agreements with the United States allowing for the automatic exchange of country-by-country reports. The CbC report is one element of the three-tiered standardized approach to transfer
See MoreRussia reduces the interest rate from July 2019
On 26 July 2019, the Russian Central Bank announced the decision to reduce the key rate from 7.50% to 7.25% with effect from 29 July 2019. For tax purposes, the key rate is important in relation to the safe harbor rates for interest income
See MoreSaudi Arabia signs MCAA for the exchange of CbCR
On 6 August 2019, Saudi Arabian Government signed the Multilateral Competent Authority Agreement (MCAA) for the exchange of Country-by-Country reports (CbCR). According to OECD, total signatories to the agreement CbC MCAA are now 80.
See MoreBulgaria approves new mandatory TP documentation requirements
On 31 July 2019, the National Assembly approved at second (final) reading amendments to the Tax and Social Security Procedure Code (TSSPC), which introduced the new transfer pricing (TP) documentation requirements. New rules for TP
See MoreFrance: President signs new Law of digital services tax
The new Law No. 2019-759 has been published on July 25, 2019, in the Official Gazette, which introduces Digital Services Tax (DST). It was signed by the French President, Emmanuel Macron, on July 24, 2019. This new Law also modifies the downward
See MoreEcuador introduces TP risk model
On 1 August 2019, the Inter-America Center of Tax Administration (CIAT) publishes a document on Ecuador Transfer Pricing (TP) Risk Model in its official website. The SRI of Ecuador, with the coordinated support of CIAT, the United Nations (UN), the
See MoreTransfer Pricing Brief: August 2019
MalaysiaRestriction on interest deduction: On 5 July 2019, the Inland Revenue Board of Malaysia has published new guidance on restrictions to the deductibility of interest expenses. Under the rules the maximum amount of deductible interest is
See MoreIndia legislates Finance (No. 2) Act 2019
On 1 August 2019, India has published the Finance (No. 2) Act 2019 in the Official Gazette, which was approved by the president. The measures of the Act are in line with those presented as part of the Union Budget for 2019-20. Corporate tax
See MoreQatar publishes ministerial decision about CbCR in the official Gazette
On 17 June 2019, Qatar’s Ministry of Finance published Ministerial Decision No. 16 in the official Gazette implementing new obligations of country-by-country reporting (CbCR) requirement from 2018. The decision mainly clarifies about eligible
See MoreLithuania implements EU Directive on Dispute Resolution
On 11 July 2019, Lithuania has published Law No. XIII-2310 in the Official Gazette, which includes measures for the implementation Council Directive (EU) 2017/1852 of 10 October 2017. This includes rules to ensure effective resolution of
See MoreMalaysia: IRBM releases guidelines on restrictions to the deductibility of interest
On 5 July 2019, the Inland Revenue Board of Malaysia has published new guidance on restrictions to the deductibility of interest expenses. The restriction is provided under Section 140C of the Income Tax Act 1967 (hereinafter referred to as the
See MoreAustria implements EU Directive on Dispute Resolution
On 22 July 2019, Austria has published the EU Financial Adjustment Act 2019 in the Official Gazette, which includes measures for the implementation Council Directive (EU) 2017/1852 of 10 October 2017. This includes rules to ensure effective
See MoreCosta Rica: MOF publishes draft resolution on advance pricing agreements (APA)
On 2 July 2019, the Ministry of Finance released a draft resolution providing rules on advance pricing agreements (APA) under the OECD transfer pricing guidelines. The resolution outlined the application procedures for approval, refusal, renewal
See MorePortugal approves amendments to the TP rules
On 19 July 2019, the Portuguese parliament approved Law No. 180/2019, which includes amendments to the country's transfer pricing (TP) rules. The new law changes the following rules: Abolishing the hierarchy in the selection of the transfer
See MoreAustralia issues final PCG and ruling on hybrid mismatch rules
The Australian Taxation Office has issued Practical Compliance Guideline (PCG) 2019/6 and Law Companion Ruling (LCR) 2019/3, related to the concept of structure arrangements in relation to Australia's new hybrid mismatch rules.
See MoreIreland introduces EU Directive on Dispute Resolution
Ireland has issued Statutory Instrument (S.I.) No. 306/2019 of 5 July 2019, that includes regulations for the purpose of giving effect to Council Directive (EU) 2017/1852 of 10 October 2017 on dispute resolution. The Directive
See MoreCosta Rica: Tax authority issues guidance on transfer pricing rules
On 26 June 2019, Costa Rican tax authority published the Resolution N° 41818-H in the Official Gazette that changes Income Tax Law regulation including transfer pricing obligations. The new Regulation defines persons as related persons who are
See MoreMalta introduces EU Directive on Dispute Resolution
On 12 July 2019, Malta has published regulations in the Official Gazette implementing Directive of European Union Council Directive (EU) 2017/1852 of 10 October 2017 on tax dispute resolution mechanisms into domestic law. The regulations came
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