Canada: 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
See MoreTransfer 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
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