Zambia: 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
See MoreJapan: 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
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