Saudi 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
See MoreArgentina releases decree regarding tax reform measures for corporations
On 27 December 2018, Argentina published a Regulatory Decree 1170/2018 in the Official Journal, which entered into force on 28 December 2018. The decree prescribes policy changes to Law 27,430 of 2017, which introduced tax reform measures for 2018.
See MoreDenmark: Supreme Court rules against Ministry of Taxation in landmark Transfer Pricing case
On 31 January 2019, Denmark's Supreme Court issued its decision on a transfer pricing case regarding Microsoft Denmark ApS (Microsoft Denmark) which is a Danish subsidiary of the United States (US) software company Microsoft Corporation. In its
See MorePanama sign MCAA for the exchange of CbC reporting
On 24 January 2019, the tax authority of Panama signed the Multilateral Competent Agreement (MCAA) for the exchange of Country-by-Country (CbC) reports. The purpose of the CbC MCAA is to set forth rules and procedures as may be necessary for
See MoreKazakhstan: New guidelines of TP Documentation and APA
On 24 December 2018, Mr. Alikhan Smailov, the Finance Minister of Kazakhstan approved forms and procedures for filling the Master files and Local files, effective from January 01, 2019. Generally, the rules for Master file and Local file are in line
See MoreDominican Republic: DGII issues transfer pricing documentation thresholds for 2019
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 transaction threshold for transfer pricing reporting
See MorePanama publishes law containing transfer pricing rules for preferential tax regimes
On 26 December 2018, Panama released the Law No.69 in the Official Gazette No.28684-B which sets out the method for calculating income earned from the “transfer or exploitation” of intellectual property assets. The law also includes provisions
See MoreFinland gazettes the law implementing the controlled foreign company (CFC) rules
On 31 December 2018, a law was published on the implementation of CFC rules in line with EU directive (EU) 2016/1164 (2016) as adopted by the parliament which is incorporated into Finnish legislation as a Law No. 1364/2018. The law introduced
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