Israel 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 MoreBulgaria 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
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