Australia issues final PCG and ruling on hybrid mismatch rules
The Australian Taxation Office has issued Practical Compliance Guideline (PCG) 2019/6 and Law Companion Ruling (LCR) 2019/3, related to the concept of structure arrangements in relation to Australia's new hybrid mismatch rules.
See MoreIreland introduces EU Directive on Dispute Resolution
Ireland has issued Statutory Instrument (S.I.) No. 306/2019 of 5 July 2019, that includes regulations for the purpose of giving effect to Council Directive (EU) 2017/1852 of 10 October 2017 on dispute resolution. The Directive
See MoreCosta Rica: Tax authority issues guidance on transfer pricing rules
On 26 June 2019, Costa Rican tax authority published the Resolution N° 41818-H in the Official Gazette that changes Income Tax Law regulation including transfer pricing obligations. The new Regulation defines persons as related persons who are
See MoreMalta introduces EU Directive on Dispute Resolution
On 12 July 2019, Malta has published regulations in the Official Gazette implementing Directive of European Union Council Directive (EU) 2017/1852 of 10 October 2017 on tax dispute resolution mechanisms into domestic law. The regulations came
See MoreHungary: Parliament approves exit tax and hybrid mismatch rule in line with ATAD
On 12 July 2019, the Hungarian legislator passed an anti-tax avoidance rule for the implementation exit tax and hybrid mismatch rules in line with the EU Anti-Tax Avoidance Directive (ATAD). The exit tax rules would apply from 1 January 2020
See MoreLuxembourg: Tax administration updates its CbC reporting guidance page
On 16 July 1019, the Luxembourg tax administration released its CbC reporting guidance page with new updates, including a new user manual for the MyGuichet e-filing system for submitting CbC reports and a new XSD schema (XML). Under the new manual
See MoreIndia: The new Finance Act modifies the Transfer pricing law
On 5 July 2019, the Minister of Finance presented the Finance (No.2) Act for the financial year 2019-20. The act changes the following transfer pricing rules: Documentations requirements: Under the new amendments, constituent entity of an
See MoreDenmark publishes a notice regarding transfer pricing documentation
On 12 July 2019, the Danish Tax Authority has published a notice (SKM2019.374.SKTST) which establishes a new practice for the importance of whether a transfer pricing documentation in its entirety is available at the time of tax return. The
See MoreLatvia publishes regulations for low value-adding intra-group services
On 9 July 2019, Latvia published Cabinet Regulations No. 324 of 9 July 2019 in the Official Gazette addressing simplified transfer pricing provisions for intra-group low value-added services. The Regulation provides that the general
See MoreDenmark implements EU dispute resolution directive
The Act implementing Council Directive (EU) 2017/1852 of 10 October 2017 in Denmark entered into force on 30 June 2019. The Directive contains provisions on the effective resolution of disputes concerning the interpretation and application of
See MoreIceland: MOF Seeks Comments on draft CbC reporting regulations
On 12 July 2019, the Ministry of Finance and Economic Affairs has opened a public consultation on draft CbC reporting regulations. The draft regulation includes the measures outlining the income, taxes, and economic activities of multinational
See MoreUS: IRS updates instructions for Country by Country reporting form
On 10 July 2019, IRS published the updated instructions for filing Form 8975 (Country-by-Country Report). Key changes are highlighted below; IRS Updates Mailstop for U.S. MNEs Filing Form 8975 on Paper: If a U.S. multinational enterprise
See MoreUkraine: SFS clarifies treatment of controlled transactions with Bulgaria
On 20 June 2019, the Ukraine State Fiscal Service published a guidance letter No. 2826/6/99-99-15-02-02-15/IPC defining the treatment of transactions with residents of tax Bulgaria, which was removed from the Cabinet tax haven list in April
See MoreSweden transposes EU Directive on Dispute Resolution
On 19 June 2019, a law proposal that implements the EU Tax Dispute Resolution Directive (2017/1852) was presented to the parliament to be transposed into Swedish legislation. If passed, the law will enter into force on November 1,
See MoreBangladesh enacts Budget for 2019-20
On 30 June 2019, Parliament passed the Tk 5,23,190 crore national budget for 2019-20 fiscal year. The proposals were enacted by the Finance Act, 2019 (the Act) and became effective as of 1 July 2019. The summary of key amendments introduced by
See MoreNetherlands: Cabinet submits new bill against tax avoidance
The Dutch government published a legislative proposal engaging rules to counter hybrid mismatches into the Dutch corporate income tax act pursuant to the EU Anti-Tax Avoidance Directive as agreed upon in May 2017 (ATAD2). ATAD2 would address tax
See MoreTransfer Pricing Brief: July 2019
PanamaCbC reporting requirement-General rule: On 27 May 2019, Panama introduced Country-by-Country (CbC) reporting requirements for MNE’s whose consolidated group revenue exceeds €750 million. Timing: The CbC report must be filed no
See MoreIndia presents Finance Bill for 2019/20
On 5 July 2019, the Finance Minister presented the Finance Bill of the newly formed government for financial year (FY) 2019-20. The bill proposed changes to the tax laws starting 1 April 2019. The proposed key amendments includes: The rate of
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