Mexico: Tax authority updates the transfer pricing adjustment rules
Recently, the Mexican tax authorities issued the Second Resolution of modifications to the 2018 Miscellaneous Tax Resolution (MTR) in which the rules regarding transfer pricing adjustments were amended and certain additional provisions were
See MoreIndia: CBDT publishes second APA annual report
The Central Board of Direct Tax (CBDT) released the second annual report (2017-18) of its advance pricing agreement (APA) programme on 31 August 2018. The report introduced a report card of the performance of the programme along with qualitative and
See MoreBrazil: RFB clarifies Transfer pricing rules on import of products
On 30 august 2018, the Department of Federal Revenue of Brazil (RFB) published a ‘Private Ruling 95/2018’ in the Official Gazette which clarifies the calculation of price parameter on import of steel product for resale. Under this Private Ruling
See MoreSweden: Tax Agency updates Transfer Pricing Guidance on Profit Splits method
On 29 August 2018, the Swedish Tax Agency (Skatteverket) has updated its transfer pricing guidance to incorporate the OECD guidance on the application of the transactional profit split method, which was revised as part of the work for BEPS Action
See MoreFinland: Ministry of Finance issues a draft bill proposing amendments to the CFC rules.
On 6 August 2018, the Finnish MoF published a draft consultation on a draft law that proposed changes to the Finnish CFC rules. The draft law aims to implement the CFC provisions contained in the EU ATAD. The bill would introduce changes to the CFC
See MoreU.S. and Austria sign an agreement on the exchange of country-by-country reports
According to an IRS announcement on its website, the competent authorities of U.S. and Austria have concluded an arrangement on the exchange of Country-by-Country Reports. The competent authority arrangement (CAA) for exchange of country-by-country
See MorePoland: Ministry of Finance declares key changes under 2019 tax reform
Poland’s Ministry of Finance announced, significant changes in the tax law are planned in Poland as of 2019. The Ministry announced the following key measures, among others: Stricter conditions for the application of withholding tax exemption
See MoreAustralia: Parliament adopts hybrid mismatch legislation
On 16 August 2018, Treasury Laws Amendment (Tax Integrity and Other Measures No. 2) Bill 2018 containing the hybrid mismatch integrity measures was passed by the Parliament. The bill includes the measures to prevent entities that are liable to
See MoreSwitzerland: Federal Council adopts dispatch on BEPS convention
The Federal Council adopted the dispatch on the multilateral convention to implement tax treaty related measures to prevent base erosion and profit shifting (BEPS) on 22nd August 2018. The dispatch was submitted to Parliament. Switzerland signed the
See MoreCroatia: MoF publishes a draft bill covering various sectors
The Finance Minister, Zdravko Marić, on August 16, 2018, published draft bill on amendments to the Law on administrative cooperation in tax matters. This Act shall enter into force on the eighth day after its publication in the Official Gazette
See MoreHong Kong signs multilateral competent authority agreement on exchange of CbC reports
Hong Kong joined the multilateral competent authority agreement on the exchange of country-by-country reports (CbC MCAA). The CbC MCAA was signed by Hong Kong on 27 July 2018. The purpose of the CbC MCAA is to set forth rules and procedures as may
See MoreEgypt reduces late payment interest, penalties and additional taxes if taxes are settled
On 15 August 2018, the Egyptian Government has issued new Law no. 174 of 2018 (the Law) that reduces late payment interest and penalties by a certain percentage based on the payment day of the taxes due. The law introduces 90% reduction on interest
See MoreGermany: Ministry of Finance confirms exchange of CbC Reports with the U.S. for 2016
On 16 August 2018, The German Ministry of Finance published a letter on the spontaneous exchange of CbC reports between Germany and the United States (US) concerning reporting fiscal year 2016. This follows a joint statement between Germany and the
See MoreKazakhstan: Ministry of Finance releases draft bill to ratify MLI
The Finance Ministry has published a draft bill on August 1, 2018, for ratifying the Multilateral Convention to Implement Tax Treaty Related Measures to Prevent BEPS (MLI). Generally, for a particular covered agreement, the MLI will enter into force
See MoreMalta updates guidelines on the application of the notional interest deduction (NID) rules
On 8 August 2018, the Maltese Commissioner for Revenue published update guidelines on the application of the notional interest deduction (NID) rules. Under the NID, a Malta company or partnership, including a Malta permanent establishment of a
See MoreSingapore: IRAS publishes e-tax guide on country-by-country reporting
On 7 August 2018, the Inland Revenue Authority of Singapore (IRAS) published the third edition of its e-Tax Guide concerning country-by-country reporting. The purpose of the guide is to provide information to the taxpayers regarding the obligation
See MoreFinland: Ministry of Finance officially submits its budget proposal for the year 2019
On 9 August 2018, the Ministry of Finance officially submitted its budget proposal for next year 2019. The budget introduced changes to the CFC definition and applicable exemptions, including reducing the control threshold for a company that
See MoreNigeria: Areas where CCAs may conflict with domestic law
The Government has observed almost six years of significant efforts to align its domestic tax laws and regulations with international initiatives on modernization of its tax principles and enhancement of transparency and disclosure requirements.
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