India: CBDT signs 18 new APAs
On 3 April 2019, the Central Board of Direct Taxes (CBDT) has announced the signing of 18 advance pricing agreements (APAs) during March 2019, including three bilateral APAs. With the signing of these APAs, the total number of APAs entered into
See MorePeru: SUNAT issues a new transfer pricing guideline on related-party share transfers
On 16 May 2019, Peruvian tax administration published a guidance “Informe No. 057-2019-SUNAT/7T0000” outlining the tax treatment of transfers of undervalued Peruvian entity shares involving foreign related parties. Under this any transfer
See MoreAustria: MoF proposes draft legislation regarding tax reform for 2019-2020
On 8 May 2019, the Austrian Ministry of Finance published a draft bill regarding tax reform for 2019-2020. The main measures of the draft bill are following: -A reduction in the corporate tax rate from 25% to 23% in 2022 and to 21% in
See MoreHungary: NTC publishes a notice to remind taxpayers for deadline of TPD
On 8 May 2019, the Hungarian National Tax and Customs Administration issued a notice to remind taxpayers that they must prepare their transfer pricing documentation by 31 May 2019 if they are required to keep transfer pricing records and closed
See MorePortugal legislates the EU ATAD into domestic law
On 3 May 2019, Portugal published Law n. 32/2019 in the Official Journal which introduced amendments to the Portuguese Tax Law in line with the European Union (EU) Anti-Tax Avoidance Directive (ATAD) provisions. The law amends the following
See MoreBelgium extends deadline for filing CIT return
The tax authority of Belgium has declared corporate income tax (CIT) return filing deadlines for the 2019 tax year, with a concession for those with a deadline prior to September 26, 2019. Generally, tax returns are due by the last day of the
See MoreTransfer Pricing Brief: May 2019
JapanAudit Rules-Statute of limitation: On 27 March 2019, the Parliament of Japan adopted the legislation for the government's tax reform proposals for 2019. Accordingly, the statute of limitations for transfer pricing purposes is extended
See MorePeru: SUNAT issues a rule on Interest paid on loans from related parties
On 23 April 2019, the Tax Administration (SUNAT) of Peru issued Administrative rule 033-2019-SUNAT/7T0000 regarding the application of the Peruvian thin capitalization rules which specify a restriction of the deduction of interest on loans where a
See MoreUkraine: SFS clarifies controlled transactions between a non-resident and its PE in Ukraine
On 19 April 2019, the State Fiscal Service (SFS) of Ukraine published a guidance letter 1723/6/99-99-15-02-02-15/IPK on the treatment of transactions between a non-resident and its permanent establishment (PE) in Ukraine as controlled for transfer
See MoreIndia issues Notification on CbC exchange agreement with the U.S.
On 25 April 2019, India published Notification No. 37/2019 from the Department of Revenue in an extraordinary version of the Official Gazette. India and USA have signed a Bilateral Competent Authority Agreement and Inter – Governmental Agreement
See MoreLuxembourg: Government publishes budget law for the year of 2019
On 26 April 2019, Luxembourg published the Law of 26 April 2019 in the Official Gazette containing the measures for the 2019 budget. The law lowered the standard corporation tax rate from 18% for the financial year 2018 to 17% for the financial
See MoreLuxembourg 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
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