Australia: 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.
See MoreBelgium: Ministry of Finance publishes decree on transfer pricing documentation penalties
On 2 August 2018, the Belgian Ministry of Finance published the Royal Decree of 29 June 2018 on administrative penalties for transfer pricing documentation. Taxpayers who do not meet the reporting and registration requirements for transfer pricing
See MoreColombia issues resolution on Local file and master file submission
CbC reporting requirement-Timing: On 30 July 2018, Resolution 40 of 26 July 2018 was published in the Official Journal. Accordingly, if a constituent entity is required to submit a specific transfer pricing form (form 120), the CbCR notification
See MorePeru: Published Amendments to the Transfer Pricing Provision in the Official Gazette
Peru published the Legislative Decree No. 1369 (the Decree) on 2 August 2018 in the Official Gazette. The degree amends the transfer pricing provision of the Income Tax Law in order to be aligned with the BEPS project. The main amendments to the
See MoreJamaica: TAJ publishes practice note on final version of transfer pricing agreement
Tax Administration Jamaica (TAJ) recently published the final version of a Transfer Pricing Agreement (TPA) Practice Note. The purpose of the Practice Note is to provide taxpayers and tax officials with guidance on transfer pricing agreements in
See MoreAustralia: Improving the integrity of the thin capitalization rules
The Australian Government announced that it will implement two changes to improve the integrity of Australia’s thin capitalization rules in the 2018-19 Budget. The changes are: requiring entities to align the value of their assets for thin
See MoreSlovak Republic: President signs a Law to ratify BEPS MLI
The Slovak President, Andrej Kiska, has signed a Law on July 30, 2018, for ratification of the Multilateral Convention to Implement Tax Treaty Related Measures to Prevent BEPS (MLI). This means that Slovak Republic has completed the domestic
See MoreTransfer Pricing Brief: August 2018
Australia Rule: On 9 July 2018, ATO published draft Schedule 2 compliance guideline (PCG) 2017/1, covering ATO's compliance approach to transfer pricing issues related to centralized operational models involving procurement, marketing, sales and
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