Luxembourg deposits its MLI ratification instrument
On 9 April 2019, Luxembourg 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 for Luxembourg on the
See MoreNetherlands: Draft regulations to revise international tax ruling policy
On 23 April 2019, the Dutch Undersecretary of Finance published a draft Decree containing regulations for the previously announced new Dutch international tax ruling practice. The draft Decree would be effective 1 July 2019. A version of a revised
See MoreMexico: Tax Administration Service publishes Q&As with respect to transfer pricing comparability adjustments
On 29 March 2019, the Mexican Tax Administration Service published, on its website, frequently asked questions (Q&As) regarding transfer prices with respect to comparability adjustments. However, 15 January 2019 in Mexico City Government
See MoreUN: Draft updates to Practical Manual on Transfer Pricing
On 8 April 2019 the UN released draft updates to the United Nations Practical Manual on Transfer Pricing for Developing Countries. The updates include an important chapter relating to financial transactions. This release occurred in advance
See MoreEcuador: SRI issues circular regarding income tax law
On 9 April 2019, Ecuador’s Internal Revenue Service (SRI) issued Circular No. NAC-DGECCGC19-00000003. The circular makes a reminder about the application of the legal regulations in force for the determination of income tax for the fiscal year
See MoreItaly plans to reduce tax rates
The Italian Government is considering reducing corporate and individual income tax rate. This would reduce the standard corporate tax rate to 20% from 24%. Individual income tax rate may change from the current five-bracket system with a top rate
See MoreCyprus: House of Representatives approves law for ATAD Interest Limitation, CFC, and GAAR Rules
On 5 April 2019, the Cyprus House of Representatives passed a law that addresses certain provisions of the EU anti-tax avoidance directive (ATAD 1) particularly the interest limitation rule, a general anti-avoidance rule (GAAR) and controlled
See MorePoland: Government publishes draft bill introducing simplified APA procedure
On 22 March 2019, Poland’s legislative centre published a draft bill that addresses dispute resolution of double taxation issues and advance pricing agreements (APAs). Under this taxpayers will be benefited from the new procedure on Simplified
See MoreUkraine: SFS issues letter on transfer pricing rules to salaries paid to non-residents
On 29 March 2019, the State Fiscal Service (SFS) of Ukraine issued letter 1358/6/99-99-15-02-15/ІPK on the treatment of salary payments to non-resident persons as controlled for transfer price purposes. The letter states that such payments
See MoreUganda: Minister of Finance presents tax reform bills to Parliament
On 28 March 2019, Mr. Matia Kasaija, the Minister of Finance, Planning and Economic Development (Minister of Finance) of Uganda presents a number of tax reforms amendment bills to the Ugandan parliament and are currently under consideration. The
See MoreUS: JCT releases overview of the limitation on the deduction of business interest
On 28 March 2019, the U.S. Joint Committee on Taxation (JCT) published an overview of the limitation on the deduction of business interest expense under Section 163(j) of the Internal Revenue Code as introduced by the Tax Cuts and Jobs Act. The new
See MoreZambia: Tax Appeals Tribunals decision on arm’s length arrangements between related parties
Recently, the Tax Appeals Tribunal (TAT) issued a decision for the Zambia Revenue Authority (“ZRA”) in the case of: Nestlé Zambia Trading Limited v. Zambia Revenue Authority TAT 03, regarding transfer prices used with respect to its
See MoreGermany updates Guidance on CbC reporting requirements
The German Ministry of Finance issued an updated version of the Application Decree on the General Tax Code on 5 April 2019. The updated version provides for guidance on the application of section 138a of the General Tax Code (GTC) by the tax
See MoreIndia: CBDT publishes new deadline for CbC Report Local Filing for U.S. MNEs
On 8 April 2019, the Central Board of Direct Taxes(CBDT) has issued Circular 7/2019 regarding the constituent entities of U.S. MNEs are required to submit Country-by-Country (CbC) reports in India by 30 April 2019. The circular notes that
See MoreAustralia issues draft ruling on thin capitalization
On 5 April 2019, the Australian Taxation Office (ATO) released a draft ruling TR 2019/D2 with respect to the requirements for the application of the arm’s-length debt test (ALDT) in the thin capitalization rules. The draft ruling proposes that
See MoreDenmark approves deadlines for preparing, submitting transfer pricing documentation
Recently, the Danish parliament adopted an important amendment of the Tax Control Act (L 13 Forslag til Skattekontrollov of October 4, 2017) that is in force from January 1, 2019 with regard to transfer pricing documentation. The purpose of the
See MoreUruguay extends CbC Reporting deadline to 30 April 2019
According to Resolution No. 860/2019 of 27 March 2019, Uruguay's Directorate General of Taxation has extended the deadline for the submission of Country-by-Country Report (CbCR) to 30 April 2019 in respect of the reporting fiscal year ending 31
See MoreTransfer Pricing Brief: April 2019
FinlandRestriction on interest deduction: On 7 March 2019, the Finnish tax administration published new guidelines on the rules on interest deduction restrictions, which were amended to comply with EU Anti-Tax Avoidance Directive (ATAD), and
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