Luxembourg: EU General Court upholds EC Commission’s decision in Fiat case
On 24 September 2019, the EU General Court upheld the Commission’s decision that Fiat received unlawful State aid from Luxembourg, and at the same time cancelled the decision which had found the same with respect to Starbucks in the
See MoreGreece: AADE publishes Circular 1341 / 09-09-2019 on CbC notification process
On 17 September 2019, the Greek Public Revenue Authority (AADE) released a Circular 1341 / 09-09-2019 containing amendments to Decision POL. 1184 of 22 November 2017 regarding the submission process of CbC notifications. Under this new Circular,
See MoreBelgium announces compliance for pre-filing requests regarding TP
The Belgian ruling commission has announced that pre-filing requests or ruling requests concerning Transfer Pricing (TP) or the patent income deduction regarding the corporate income tax return that will be filed by the end of September 2020 must
See MoreGermany publishes new draft of DAC 6 implementation law
On 26 September 2019, federal government of German issued a draft proposal regarding the implementation of mandatory disclosure rules pursuant to the EU’s Council Directive 2018/822 of 25 May 2018 (commonly referred to as DAC 6) into Germany’s
See MoreNigeria: 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
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