Bulgaria proposes changes to the Corporation Tax Act
On 12 November 2019, a proposal to changes the Corporation Tax Act was submitted to Parliament. The law proposed the following measures: propose to amendments the thin capitalization rules in order to increase the level of expenditure that is
See MoreCzech Republic: Government approves draft bill regarding digital service tax
On 18 November 2019, Government approved a draft bill regarding digital service tax (DST), which responds to the dynamic development of digital economy services and straightens the conditions in the Czech tax environment. The Ministry of Finance
See MoreAustralia extends TP document submission deadline
Significant global entities (SGEs) that have a CbC reporting obligation in Australia for the year ended 31 December 2018 required that their local file (LF), master file (MF), and CbC report are due to be lodged by 31 December
See MoreCosta Rica publishes a resolution outlining guideline on transfer pricing documentation
On 13 November 2019, the Costa Rican tax authority released a Resolution No.DGT-R-49-2019 providing new guidelines on transfer pricing documentation including master file and local file. The new resolution repeal the resolution DGT-R-16-2017
See MoreCroatia: Government publishes transposition Bill regarding DAC6
On 31st October 2019, the Government published a bill regarding the implementation of mandatory disclosure rules pursuant to the EU’s Council Directive 2018/822 of 25 May 2018 (commonly referred to as DAC6) into Croatian’s domestic law. Under
See MorePortugal: Administrative Court issued a decision on Transfer Pricing case
On 10 October 2019, in the case of : n.º 511/2018-T, the Administrative Court issued a decision on the sale of raw materials and goods by a company to related parties. In particular, concerning an undervalued controlled transaction tested using
See MoreSerbia: Parliament adopts draft bill to implement CbC reporting obligations
On 18 October 2019, the Serbian parliament accepted for consideration a bill to implement country-by-country (CbC) reporting obligations for multinational entities (MNEs). Under this ultimate parent entities of an MNE group resident in Serbia are
See MoreGhana: Finance Minister presents 2020 Budget
On 13 November 2019, Finance Minister, Mr. Ken Ofori-Atta, has presented the New Patriotic Party (NPP) government’s fourth Budget Statement and Economic Policy to Parliament which he said is focused on providing liquidity to boost
See MoreKazakhstan: Lower house of parliament approves ratification of BEPS MLI
On 30 October 2019, the lower house of Parliament (Mazhilis) approved the ratification of the Multilateral Agreement on the Implementation of Tax Treaty Related Measures to Prevent Base Erosion and Profit Shifting (MLI). It was approved by the
See MoreBulgaria submits proposal to amends the TP documentation threshold
On 12 November 2019, some of policy makers submitted to Parliament a proposal to amend the rules on thresholds for the Transfer Pricing (TP) documentation rules. It is proposed that the obligation to prepare such documents will not apply to persons
See MoreLatvia deposits its Multilateral Convention ratification instrument
On 29 October 2019, OECD confirmed that Latvia deposited its instrument of ratification for the multilateral convention to implement tax treaty related measures to prevent base erosion and profit shifting (BEPS MLI). The MLI is a multilateral tax
See MoreMalta updates notional interest deduction (NID) guidelines
On 7 November 2019, the Maltese Commissioner for Revenue has updated notional interest deduction (NID) guidelines. The guidelines address a new paragraph regarding attribution of the deemed interest income on alternative bases. The following
See MoreAustria implements the Mandatory Disclosure Rules
On 22 October 2019, the government of Austria officially published the EU-Mandatory Disclosure Act implementing the European Union (EU) Directive on the mandatory disclosure and exchange of cross-border tax arrangements (DAC6). Under DAC6,
See MoreSlovenia publishes amendments to the CITA in the Official Gazette
On 5 November 2019, the Slovenian government published the amendments to the Corporate Income Tax Act (CITA) in the Official Gazette.
See MoreMexico: Congress approves tax reform package for 2020
On 30 October 2019, Mexico’s Congress has approved the tax reform for 2020 which was presented by President Andrés Manuel López Obrador’s on September 8, 2019. The Reform incorporates fundamentals of the Base Erosion and Profit Shifting
See MoreIreland: Finance Minister publishes draft law regarding mandatory disclosure rules
On 17 October 2019, the Finance Minister published draft legislation as part of Finance Bill 2019 for the implementation of European Union (EU) Directive 2018/822 regarding mandatory disclosure and exchange of cross-border tax arrangements (DAC6)
See MoreTransfer Pricing Brief: November 2019
SloveniaMain corporate income tax rate: Slovenia increased the corporate income tax rate from 19% to 20% with minimum tax rate 7% under the amendments of corporate income tax act. Special rules for hybrid instruments or entities: Slovenian
See MoreSpain launches a public consultation on DAC6 reporting requirements
On 21 October 2019, the Spanish Ministry of Finance has launched a public consultation on the draft regulation approving the model forms to be used in the context of the implementation of Council Directive (EU) 2018/822 of 25 May 2018 (DAC6) on
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