Argentina enacts regulation to implement the tax reform
On 4 December 2018, Argentina enacted Law 27,430 (the Act), which contains proposals for the implementation of the tax reform. The law introduced the taxation of indirect transfers of assets located in the country, pointing out that transfers within
See MorePuerto Rico: Governor sign the law of tax reform bill
On 10 December 2018, Puerto Rico Governor Ricardo Rosselló signed into law Bill No. 1544 as Law No. 257 of 10 December 2018. Under the reform bill, the regular corporate tax rate has been reduced from 20% to 18.5% starting from taxable year after
See MoreCosta Rica passes tax reform bill
On 4 December 2018, Costa Rica passed a tax reform bill which includes several tax reform measures. Interest limitation rule: Under the law, an interest limitation rule applies which interest expenses that exceed 20% of the taxpayer's
See MoreNigeria: Alerting TP compliance regulation deadline
The Federal Inland Revenue Service (FIRS) of Nigeria declared 31st December as the last date for the taxpayers for complying the pending transfer pricing obligations and also submitting the documentations which include the disclosures of all related
See MoreSaudi Arabia: General Authority of Zakat and Tax (GAZT) publishes draft transfer pricing law
On 10 December 2018, General Authority of Zakat and Tax (GAZT) released draft transfer pricing regulations (TPBy-laws) for public consultation. The regulations broadly follow international standards, including the arm’s-length principle and
See MoreBelgium extends transfer pricing documentation deadline
On 7 December 2018, the Federal Service for Finance of Belgium extended the deadline for submitting master file (275MF) and local file (275LF) from 31 December 2018 to 28 February
See MoreThailand: New Transfer Pricing Law effective from January 2019
On 21 November 2018, the Transfer Pricing Act of Thailand was published in the Royal Gazette and will be effective for accounting years beginning on or after 1 January 2019. Taxpayers with related parties, regardless of having related-party
See MoreSweden:Tax Authority declares on the relevance of the TP documentation when filing an incorrect tax return
On 3 December 2018, the tax authority issued Declaration No. 202 251680-18 / 111, on the relevance of Transfer Pricing documentation in the event of a tax surcharge for providing incorrect information. If the company has made an inaccurate task
See MoreSingapore enacts the Income Tax (Amendment) Act 2018
On 12 November 2018, Singapore enacted the Income Tax (Amendment) Act 2018. The Act(amended) implements the changes in income tax announced in the 2018 budget statement and changes in the taxes resulting from the regular review of income tax
See MoreTanzania: Government issues new Transfer Pricing Regulations 2018
On April 27, 2018,Government has published new Income Tax (Transfer Pricing) Regulations of 2018. The regulations have issued on November 2018, which replaces the Income Tax(Transfer Pricing) Regulations 2014. This provides extra requirements
See MoreBulgaria includes new CFC rule and updates interest limitation rule
On 27 November 2018, Bulgaria published a Bill on amendment and supplement to the Corporate Income Tax Act in the Official Gazette. The Bill includes a new interest limitation and controlled foreign company (CFC) rules in accordance with the EU
See MoreBelgium issues draft TP guidelines for public comments
The tax authority of Belgium has published a draft Circular on the 2017 update to the Organisation for Economic Co-operation and Development (OECD) Transfer Pricing (TP) Guidelines. On 9 November 2018, the draft Circular was published by the Belgian
See MoreTransfer Pricing Brief: December 2018
Finland Control: 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
See MoreMexico: SAT publishes the Miscellaneous Fiscal Resolution for 2018
On 30 November 2018, the Tax Administration Service (SAT) published in its portal the "Fourth of Modifications to the Miscellaneous Fiscal Resolution for 2018" and its annexes. Modifications to the value of operations with related parties within the
See MoreMexico publishes the Fourth Resolution of Modifications to the Miscellaneous Fiscal Resolution for 2018
On 30 November 2018, the Fourth Resolution of Modifications to the Miscellaneous Fiscal Resolution for 2018 and Annexes 1, 1-A, 3, 7, 11 and 23 were published in the Official Gazette. Among others the modification added as a criterion in terms of
See MoreQatar 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
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