Denmark: Ministry of Taxation publishes bill to implement EU ATAD
On 28 December 2018, the Danish Ministry of Taxation has published a new legislation (Law No 1726) for the implementation of the measure of the EU Anti-Tax Avoidance Directive (ATAD1) and the Directive as amended (ATAD2). The measures
See MoreUS: IRS publishes proposed regulations on certain hybrid arrangements
On 20 December 2018, IRS issued proposed regulations implementing sections 245A(e) and 267A that were added with the enactment of the Tax Cuts and Jobs Act (TCJA). The proposed Regulations concern sections 245A (e) and 267A relating to hybrid
See MoreLithuania gazettes new Transfer Pricing rules for 2019
On 31 December 2018, the Lithuanian Official Gazette published an order for the transfer pricing (TP) rules. The new requirements generally reflect measures implementing recommendations under the OECD’s base erosion and profit shifting (BEPS)
See MoreItaly releases ATAD decree in line with EU Anti-Tax Avoidance Directive
On 28 December 2018, the Italian Government published, in the Official Gazette, the Legislative Decree (Decree) transposing the European Union (EU) Anti-Tax Avoidance Directive (ATAD) in the Italian legislation. The Government had previously
See MoreUruguay updates CbC Reporting requirements
On 4 January 2019, Uruguay's Directorate General of Taxation (DGI) has issued Resolution No. 94/2019 regarding submission of Country-by-Country (CbC) reports and notifications. Uruguay's CbC reporting requirements apply fiscal years beginning on 1
See MoreEstonia implements EU ATAD measures
On 28 December 2018, Estonia published the Income Tax Amendment Act in the Official Gazette, apply from 1 January 2019. The key measures of the Act provide the implementation of the EU Anti-Tax Avoidance Directive (ATAD) as urged by the European
See MoreAlgeria publishes finance bill 2019
On 30 December 2018, Algeria's Finance Bill 2019 was published in Official Gazette No. 79 and this Bill came into force as of 1 January 2019. The key measures introduced by the Finance Bill are following -The bill clarifies provisions regarding
See MoreTransfer Pricing Brief: January 2019
Costa Rica Interest limitation rule: On 4 December 2018, Costa Rica passed a tax reform bill which includes several tax reform measures. Under the law, an interest limitation rule applies which interest expenses that exceed 20% of the
See MoreRomania updates CFC and restriction on interest deduction rules
Romania has published Law no. 30 of 10 January 2019, which amendments restriction on interest deduction rules. The amendments increase safe harbor threshold from the RON equivalent of EUR 200,000 to the RON equivalent of EUR 1 million. It also
See MoreFinland: Ministry of Finance publishes law on interest restriction rules
On 27 December 2018, Finland published Law 1237/2018 in the Official Gazette concerning new interest deduction restriction rules that are compliant with the EU Anti-Tax Avoidance Directive (ATAD). The law extends the limitation to interest paid on
See MoreMalaysia: Parliament passes Finance bill 2018 (Budget 2019)
On 10 December 2018, the House of Representatives passed the Finance Bill 2018 which was published in the Federal Gazette on 27 December 2018. The key changes of Finance Bill 2018 are summarized below: Corporate Tax Changes The limitation
See MoreJapan: MLI enters into force
On 1 January 2019, the Multilateral Convention to Implement Tax Treaty-Related Measures to Prevent BEPS (‘Multilateral Instrument’ or ‘MLI’) entered into force in respect of Japan. The MLI was signed by Japan on 7 June 2017. As of 1 October
See MorePeru releases decrees regarding deduction of expenses related to intra-group services
On 30 December 2018, the Peruvian Minister for Economic Affairs issued Supreme Decree 337-2018-EF and Supreme Decree 339-2018-EF, which contains provisions on the deduction of expenses for intra-group services and the definition of
See MoreJapan proposes tax reform plans for 2019
On 14 December 2018, Japan's ruling coalition party has approved a package of tax reform proposals for 2019. The proposal includes amendments to Japan’s controlled foreign company (CFC), interest expense limitation, and general transfer pricing
See MoreIndia: Ministry of Finance issues CbC report extension deadline
On 26 December 2018, India’s Ministry of Finance released a Circular, which provides for an extension of the deadline for non-parent constituent entities in India to submit a Country-by-Country (CbC) report where secondary local filing is
See MoreCyprus extends the deadline for submission of CbC report for FY 2017
On 18 December 2018, the tax department declared that the deadline for submission of CbC reports for reporting financial year 2017, which was due on 31 December 2018, was extended until 31 January 2019. The extension also applies to constituent
See MoreLuxembourg: Parliament passes draft law implementing EU Anti-Tax Avoidance Directive
On 18 December 2018, the Luxembourg Parliament passed draft law No 7318 (the Law) implementing the EU Anti-Tax Avoidance Directive (ATAD), which sets out limitation to interest deductibility, the provisions on controlled foreign companies ( CFC) and
See MoreDenmark: Ministry of Taxation publishes draft tax proposal to ratify BEPS MLI
Recently, the Danish Ministry of Taxation is inviting public comments on a draft legislative proposal to ratify the OECD’s Multilateral Instrument (MLI) to implement tax treaty-related measures to tackle base erosion and profit shifting. The draft
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