Transfer Pricing Brief: March 2019
Hong Kong CbC reporting requirement-General rule: On 1 February 2019, Hong Kong Inland Revenue Department (IRD) announced that effective from 1 April 2019, the department will not accept voluntary filing of a CbC return for an accounting period
See MoreHong Kong: IRD publishes 2018/19 profits tax returns and supplementary forms
On 18 February 2019, the Hong Kong Inland Revenue Department (IRD) has published the sample Profit Tax Returns for 2018/2019 including new Transfer Pricing Disclosure Form and other supplementary forms. The supplementary forms are also provided for
See MoreChile: IRS amends the annual transfer pricing form
The Internal Revenue Service (IRS) has issued a new version of the annual transfer pricing tax return (Form 1907) to be used in 2019, and includes new sections on Country Reporting (CbC). The IRS also added the instructions of the 1907
See MoreSouth Africa introduces Budget 2019 in parliament
On 20 February 2019, Tito Mboweni (South Africa’s Minister of Finance) presented the Budget 2019 in the parliament. The budget proposal would not increase taxes in any category but proposed to increase tax collection by not adjusting for inflation
See MoreEgypt publishes a draft of Consolidated Tax Procedures Act
On 17 February 2019, the Ministry of Finance of Egypt has published a draft consolidated tax procedures Act for public discussion. The Act aims to facilitate the procedures related to the collection of various taxes to prevent multiple procedures
See MoreIreland: Public consultation on new transfer pricing regime
On 18 February 2019, Department of Finance of Ireland released the public consultation document to update transfer pricing regime, with an effective date of 1 January 2020. The consultation looks for feedback on a number of aspects of existing
See MorePortugal: Parliament proposes to implements The Anti-Tax Avoidance Directive
Recently, the Portuguese Government has submitted to Parliament the Bill No.177/XIII introducing changes to the Income Tax Act to implement certain ATAD-1 rules. The bill proposed rules for the limitation of interest deductions and rules for
See MoreSaudi Arabia: GAZT approves the transfer Pricing Law
On 15 February 2019, the Board of Directors of General Authority of Zakat and Tax (GAZT) of Saudi published a resolution approving transfer pricing Bylaws as well as an additional FAQs document. The law consists of 26 articles, divided into 12
See MoreDominican Republic: DGII updates transfer pricing brochure
On 7 February 2019, The Dominican Republic’s Directorate General of Internal Revenue (DGII) published online brochure to update guidance on transfer pricing. The brochure makes a number of following changes on transfer pricing: Reporting
See MoreSweden: Proposal for the extension of the hybrid match rules submits for comments
On 1 February 2019, the Ministry of Finance has sent a memorandum on referral with a proposal to extend the so-called hybrid rules. The purpose of the rules is to prevent differences in countries legislation being used in cross-border arrangements
See MoreBelgium updates TP reporting penalties
On 8 February 2019, the Belgian Federal Public Service (SPF) Finance published Circular Letter No. 2019/C/14 regarding penalties due if a taxpayer fails to fulfill its transfer pricing (TP) reporting obligations. The Circular Letter is an annex to
See MoreColombia: DIAN publishes transfer pricing return and other forms for 2019
On 15 January 2019, Directorate of Taxes and National Customs (DIAN) of Colombia published Administrative Regulation 000004 of 2019 to provide the following form for filing a 2019 tax return: Informative transfer pricing return (Form 120);
See MoreBrazil: RFB updates TP rules on import transaction and commodities
On 29 January 2019, the Brazilian Federal Revenue Department (RFB) issued Normative Instruction (NI) 1870/2019 amending NI 1312/2012 effective as of calendar year 2019. The amendments are mainly related to import transaction and commodities and some
See MoreCroatia: Finance Minister declares related party interest rate for 2019
The Croatian Minister of Finance, referring to National Gazette 118/2018 of 27 December 2018, has declared to reduce the interest rate on loans between related parties from 4.55% to 3.96% per annum. The reduction of so called the arm’s length
See MoreBelgium: Parliament approves new restriction on interest deduction
On 31 January 2019, the parliament of Belgium approved legislation implementing the 30% of Earnings before interest, tax, depreciation and amortization (EBITDA) restriction on interest deduction to 1 January 2019. The restriction is according to the
See MoreHong Kong: IRD plans to close voluntary filing of CbC report from 1 April 2019
On 1 February 2019, Hong Kong Inland Revenue Department (IRD) announced that effective from 1 April 2019, the department will not accept voluntary filing of a CbC Return for an accounting period ended on or before 31 March 2018. Under section 58E(2)
See MoreTransfer Pricing Brief: February 2019
Dominican Republic Documentation-Thresholds: On 17 January 2018, Directorate General of Internal Revenue (DGII) published the Transfer pricing (TP) reporting threshold for 2019. The DGII has issued Notice 8-19, which prescribes related party
See MoreRussia: Finance Ministry publishes Guidance on MAP
On 30 January 2019, the Russian Ministry of Finance published on its official website a guidelines on the mutual agreement procedure (MAP) provided for in double taxation agreements. The guideline contains recommendations for the initiation and
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