Qatar signs MLI to implement tax treaty regarding BEPS measures
The OECD announced on December 4, 2018, that Qatar has signed the Multilateral Convention to Implement Tax Treaty Related Measures to Prevent Base Erosion and Profit Shifting (BEPS). Qatar is the 85th jurisdiction to join the treaty. This treaty
See MoreBrazil: Revenue Authority publishes new Normative Instruction regarding MAP
On November 29, 2018, the Revenue Authority published Normative Instruction No. 1846 of 28 November 2018 that covers the rules for submitting a Mutual Agreement Procedure (MAP) request, the approval of a request, and the termination process. It
See MoreBrazil: Tax tribunal publishes a decision on costs included for resale price method
On November 20, 2018, the Administrative Tribunal for Federal Tax Cases (CARF) has published Decision 1402003338 of 14 August 2018. This decision states that all the expenses regarding freight, insurance, and customs need to include when allowed by
See MoreVietnam considering amendments to rules that limit related-party interest deductions
According to recent reports, the Vietnam Ministry of Finance is considering proposed amendments to the country's interest expense deduction restriction. The Decree No. 20/2017/ND-CP, enacted 24 February 2017 (Decree 20), limits deductions
See MoreChina: CbC reporting requirement for certain outbound MNCs alleviated
China has initiated country-by-country (CbC) reporting and exchange relationships with 44 countries. China expands current exchange relationship with the UK, France, and Germany. For Chinese outbound multinational companies (MNCs), the expanded CbC
See MoreAustralia: ATO extends deadline to file CbC reports
Significant Global Entities (SGE) that have a Country-by-Country (CbC) reporting obligation for the year ended 31 December 2017 will be aware that the Local file, Master file, and CbC report are due to be lodged by 31 December 2018. However, due
See MorePoland: President signed an act including amendment of TP measures effective in 2019
On 14 November 2018, President of Poland signed an act including amendment of transfer pricing measures effective in 2019. The new laws repeal the Article 9a of the CIT Act regarding transfer pricing, which is being replaced by Chapter 1a,
See MoreThailand enacts Transfer pricing law
On 21 November 2018, Thailand's new transfer pricing law was enacted and published in the Official Gazette and will be effective from 1 January 2019, which was approved by the National Legislative Assembly in 27 September 2018. Tax assessment
See MoreDenmark: Court imposes fines for not providing timely submission of TP documents
On 19 November 2018, the Danish tax authority published an overview of a decision by the Copenhagen Court on whether a company acted in a grossly negligent act for failing to submit the timely submission of transfer pricing (TP) documents and should
See MoreEgypt: Ministry of Finance publishes new decree 547 outlining new updated TP guidelines
On 21 October 2018, Egyptian Ministry of Finance has issued new decree 547 providing the authority for new transfer pricing guidelines to be published. The new guidelines introduced three-tiered level of transfer pricing reports for transparency to
See MoreUruguay issues guidance of new TP documentation requirements
In October 2018, the government of Uruguay issued Decree No. 353/2018 providing regulatory guidance regarding new transfer pricing (TP) documentation requirements. The decree clarifies guidance to implement the transfer pricing documentation
See MoreBulgaria: MoF proposes new mandatory documentation rule for transfer pricing
On 5 November 2018, the Ministry of Finance (MoF) published a draft consultation, proposing new mandatory documents for transfer pricing documentation, and a penalty for failure to comply with up to 1% of the value of undocumented transactions. The
See MoreBulgaria: Parliament approves budget 2019 at first reading
On 7 November 2018, the National Assembly passed the 2019 Budget Act at first reading with 115 MPs in favor and 85 opposed. The budget proposal containing amendments to the corporate tax laws. The proposed corporate income tax amendments are
See MoreFinland: Ministry of Finance submits a bill on changes to CFC rules to Parliament
On 1 November 2018, the Ministry of Finance submitted a bill to Parliament proposing changes to the CFC rules. Under the proposed rules, the control threshold setting the CFC status would be reduced from 50% to 25%, and the direct or indirect
See MorePeru: SUNAT extends deadline for submission of CbC report to March 2019
On 11 November 2018, Peruvian tax authorities (SUNAT) published Ruling No. 264-2018 SUNAT which extended the due date for submitting CbC report from November 2018 to March 2019 for fiscal year 2017. The extension applies to Peruvian taxpayers who
See MoreLatvia: Parliament adopts regulation with new requirements for transfer pricing documentation
On 25 October 2018 the Parliament approved amendments to the law ‘On taxes and duties’ which introduce in Latvia the OECD format of the transfer pricing documentation. The law was published on 14 November 2018 as the official Gazette no
See MoreArgentina: Taxpayers wait for enactment of draft decree no. 1112/2017
Government has released a draft decree No.1112/2017 for tax reform Law 27430 on December 29, 2017, but it has not officially published yet. This decree includes transfer pricing aspects, permanent establishment (PE) rules, restriction on interest
See MorePoland: Parliament passes tax reform bill for 2019 including MDR
On 26 October 2018, the upper house of the Polish Parliament (the Senate) adopted the draft bill introducing far-reaching changes to the Polish tax law, including European Union (EU) Mandatory Disclosure Rules (MDR). The main difference of the
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