Japan: Parliament enacts tax reform plans for 2019
On 27 March 2019, Japan's parliament approved the legislation for the government's tax reform proposals for 2019. Some of the main measures are following: Tax incentive: As from 1 April 2019, the tax credit rates will be revised to enhance
See MoreCzech Republic releases law Implementing ATAD with others changes
On 27 March 2019, the Czech Republic released the Law of 12 March 2019, which includes the introduction of measures to comply with the EU Anti-Tax Avoidance Directive (ATAD). The law usually enters into force on 1 April 2019. However, the taxation
See MoreCyprus publishes a draft law implementing EU directive on cross-border tax arrangements
On 19 March 2019, the Cypriot Ministry of Finance (MoF) published a draft law implementing EU Directive 2018/822/EU of 25 May 2018 on the mandatory disclosure and exchange of cross-border tax arrangements into national legislation. The Directive
See MoreIndia and USA sign inter-governmental agreement for exchange of CbC reports
On 27 March 2019, India and the US signed an Inter-Governmental Agreement for exchange of Country-by-Country (CbC) reports of multinational companies regarding income allocation and taxes paid to help check cross-border tax evasion. This
See MoreCosta Rica publishes amending resolution regarding CbC reporting
On 18 March 2019, the Government of Costa Rica published Resolution No DGT-R-008-2019 in the Official Gazette. The resolution amends Resolution DGT-R-001-2018, which regulated the information that companies headquartered in Costa Rica have to
See MoreHong Kong: IRD extends Country by Country (CbC) reporting notification
On 21 March 2019, the Inland Revenue Department (IRD) published an announcement of extending CbC notification in respect of the accounting period beginning 1 January 2018. Under this, the notification deadline for accounting period beginning 1
See MoreBelgium approves MLI
On 21March 2019, the Parliament of Belgium approved the law ratifying of the Multilateral Convention to implement double taxation avoidance agreement related measures to prevent Base Erosion and Profit Shifting (BEPS). After the
See MoreIndia: ITAT ruled that the income which is deemed to accrue or arise in India must have a territorial nexus
Recently, the Mumbai Bench of the Income-tax Appellate Tribunal (ITAT) in the case of: Fox International Channel Asia Pacific Ltd v. DCIT (ITA No.1947/Mum/2015) regarding the taxability of agency commission relating to the services rendered outside
See MoreSwitzerland approves MLI
On 22 March 2019, the Swiss Parliament approved in the final vote the ratification of the multilateral convention to implement tax treaty related measures to prevent Base Erosion and Profit Shifting (MLI). The MLI is subject to an
See MorePeru: SUNAT extends the deadline for submission of CbC reports for fiscal years 2017 and 2018
On 14 March 2019, the Peruvian tax authorities (SUNAT) issued an administrative regulation (Ruling No.054-2019) that extends the deadlines for the local filing of the CbC reports for Fiscal years 2017 and 2018. This resolution is effective as of the
See MoreSerbia: Ministry of Finance publishes safe harbor interest rates for 2019
The Serbian ministry of finance has published the Rulebook on arm’s length interest rates that are applicable for 2019, which apply to interest rates on loans and credits between associated parties. The Rulebook was published in the Official
See MoreCanada: Federal budget 2019
On 19 March 2019, Finance Minister Bill Morneau tabled in the House of Commons the Liberal Government’s Budget 2019. This budget focuses on continued economic growth, job creation, support for first-time home buyers, investments in cleaning up
See MoreIndia: ITAT decision on criteria for selecting transfer pricing comparable companies
The Kolkata Bench of the Income Tax Appellate Tribunal (ITAT) in the case of: Philips Medical Systems (P.) Ltd. v. ITO, held that an entity engaged in both manufacturing and trading activities cannot be a comparable company for benchmarking the
See MoreLuxembourg: Finance Minister presents draft budget law for 2019
On 5 March 2019, the Luxembourg Minister of Finance, Pierre Gramegna, presented to the Chamber of Deputies the draft budget law 2019 together with the draft multi-annual financial planning, for the 2019-2022 period to the Chamber of Deputies. The
See MoreNigeria: FIRS issues guidance on MAP
On 21 February 2019, Nigeria’s Federal Inland Revenue Services (FIRS) has issued guidelines on Mutual Agreement Procedure (MAP). The guidelines prescribe information regarding eligibility for MAP, access to MAP, overview of the MAP request
See MoreFinland: Tax administration publishes guidelines on interest limitation rules
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 contained a general 25% EBITDA interest deduction
See MoreUS: APMA releases new functional cost diagnostic model (FCD model) for APA submissions
On 26 February 2019, Advance Pricing and Mutual Agreement (APMA) program of IRS, released an excel based functional cost diagnostic model (FCD Model) that is developed in connection with several prior and pending Bilateral Advance Pricing
See MoreTaiwan: NTBNA publishes Guidance on Submission of TP documentation
On 26 February 2019, National Taxation Bureau of the Northern Area (NTBNA), Ministry of Finance of Taiwan has published guidance on the submission of the Master file and Country-by-Country report by MNEs. Here are the key points as follows: The
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