Bulgaria: Draft Law on implementation of hybrid mismatch and exit tax measures submits to NA
On 9 October 2019, a draft Law on “Amendment and Supplementation of the Corporate Income Tax Act” was presented to the National Assembly (NA). The bill proposes provisions transposing the exit taxation measures of the EU Anti-Tax Avoidance
See MoreIreland: Tax authority publishes a manual on MLI Tie-Breaker Rule
On October 9, 2019, the tax authorities published a guide that describes the way of how the new rule regarding the determination of treaty residence of dual-resident companies applies under the Multilateral Convention to Implement Tax Treaty
See MoreSlovak Republic: Implementing mandatory disclosure rules
On 14 October 2019, the Government of Slovak Republic published in the Collection of Laws the final legislation that transposes the Directive on Administrative Cooperation in Taxation (DAC6) commencing Mandatory Disclosure Rules (MDR). On
See MoreCyprus: Tax department publishes income tax return form for 2018
On 3 October 2019, the Cyprus tax department has published corporate income tax return form (TD4) for 2018. The basic difference between 2018 and 2017 return form is the part 3. Under this taxpayer is requested to confirm whether a Transfer Pricing
See MoreRussia: MLI enters into force
On 1 October 2019, the Multilateral Convention to Implement Tax Treaty Related Measures to Prevent Base Erosion and Profit Shifting (MLI) entered into force with respect to the Russian Federation. On 18 June 2019 the Russian Federation deposited
See MoreRussia enacts legislative changes on Transfer Pricing and MAP
On 29 September 2019, the Russian Government signed a Law no. 325-FZ (Amendments to the Tax Code of the Russian Federation) and published in the Official Gazette. The main amendments relating to transfer pricing are as
See MoreBelgium approves draft law to transpose EU directive on cross-border arrangements
On 11 October 2019, the Belgian Council of Ministers approved a draft law to transpose EU Directive 2018-822 of 25 May 2018 on reportable cross-border tax planning arrangements. The Directive includes measures to require the reporting of
See MoreIndia: CBDT amends rules to calculate interest income relating to Secondary Adjustments
On 30 September 2019, the Central Board of Direct Taxes (CBDT) has amended rule 10CB which provide for computation of interest income relating to secondary adjustments. The changes remove anomalies and clarify the compliance and computational
See MoreIreland: Govt. announces draft budget 2020
On 8 October 2019, Govt. announced draft Budget 2020. This draft Budget introduced some amendments in respect of corporate income tax, transfer pricing, dividend withholding tax, personal income tax, small and medium enterprises (SMEs),
See MoreBrazil: Federal Revenue approves Private Ruling 276/2019
On 2 October 2019, the Brazilian tax authorities released a private ruling PLR 276/2019 on tax treatment of cross-border cost sharing arrangements. The ruling provides a consultation solution that was requested by an entity whose direct parent
See MoreZambia presents the budget for 2020
On 27 September 2019, the Minister of Finance (MOF) presented the budget for 2020 to the National Assembly. Under the budget the following important amendments to the Income Tax Act will take effect from 1 January 2020: Corporate tax
See MorePeru: SUNAT publishes resolution on submission of CbC reports
On 29 September 2019, the Peruvian Tax Administration (SUNAT) has published Resolution No. 188-2019/SUNAT in the Official Gazette, through which the comprehensive system for the reception and automatic exchange of information (IR AEOI system) was
See MoreUkraine: STS clarifies on controlled transactions report
On 18 September 2019, the State Tax Service (STS) of Ukraine explained about the procedure to file report on controlled transactions for transfer pricing purposes. According to the procedure, representative office that does not meet the conditions
See MoreArgentina: AFIP announces draft transfer pricing guidance for public comments
On 2 October 2019, tax authority of Argentina (AFIP) announced a public consultation and posted on the AFIP website a draft resolution concerning transfer pricing compliance procedures. It would replace the existing transfer pricing rules in
See MoreNigeria: FIRS introduces e-filing for submitting TP returns
On 27 September 2019, Federal Inland Revenue Service (FIRS) described the way of how to submit transfer pricing (TP) returns through the electronic platform, when it is active. Now, the FIRS is get ready to automate the process of filing TP
See MoreFrance: Government presents draft Finance Bill 2020
On 27 September 2019, Government presents Finance Bill for the year 2020 and confirms the willingness to cut the income tax rate for corporate entities; to introduce the hybrid mismatch rules; to implement the EU ATAD 2 directive into domestic law;
See MoreTransfer Pricing Brief: October 2019
GreeceCbC reporting requirement: On 17 September 2019, the Greek Public Revenue Authority (AADE) released a Circular 1341 / 09-09-2019 containing amendments regarding the submission process of CbC notifications. Under this new Circular,
See MoreDenmark deposits ratification instrument for MLI
On 30 September 2019, Denmark deposited its ratification instrument for the Multilateral Convention to Implement Tax Treaty Related Measures (MLI) to Prevent Base Erosion and Profit Shifting. The MLI is designed to allow countries to swiftly add to
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