Egypt: Government publishes amends income tax law regarding transfer pricing rules
Government has published Ministerial Decree No. 221 of 2018 amending certain provisions of the Income Tax Law Executive Regulations under Ministerial Decree No. 991 of 2005 relating to transfer pricing rules on 22nd May 2018. The definition of
See MoreIndia: CBDT proposes amendments to secondary adjustment rules for transfer pricing
On 20 June 2018, the Central Board of Direct Taxes (CBDT) has announced the publication of a draft notification for amendment in Rule 10CB of the Income-tax Rules, 1962 in respect of computation of interest income pursuant to secondary adjustment
See MoreLuxembourg: Cabinet approves draft law for implementation of EU anti-tax avoidance directive
On 15 June 2018, the Luxembourg Cabinet approved a draft bill providing for measures to implement the EU Anti-Tax Avoidance Directive (ATAD). The draft bill includes the new provisions on the limitation of interest deduction, which limit the
See MoreSwitzerland publishes guidance regarding mutual agreement procedure
The Swiss State Secretariat for International Financial Matters has released guidance for mutual agreement procedure (MAP) requests under Switzerland's tax treaties. Switzerland has concluded double taxation agreements with numerous countries.
See MoreBelgium: Notification for corporate tax compliance
As the first half of 2018 almost ends, it is time to look forward to the coming second installment of prepayments. Income tax returns The income tax authorities confirmed the deadline of the filing of corporate income tax returns with a financial
See MoreAustralia: Draft PCG for Restructures of Hybrid Mismatch Arrangements
As part of the 2016-17 Federal Budget, the Australian government announced it would implement the Organisation for Economic Co-operation and Development's (OECD) Hybrid Mismatch rules developed under Action Item 2 of the OECD Base Erosion and Profit
See MoreChile: Reminder about the due date of submitting Sworn Statement of Income
The Internal Revenue Service (SII) gives a reminder to taxpayers of the due date of five Affidavit of Income. These are Forms No. 1929, 1930, 1907, 1937 and 1945, which are explained below: Sworn declaration Expiration date Form No. 1907 on
See MoreGreece: Public revenue Authority publishes a circular on MCAA
The Public Revenue Authority has published a Circular on June 15, 2018 regarding the lists of jurisdictions with which Greece wants implement the Multilateral Competent Authority Agreement on the exchange of Country-by-Country (CbC)
See MoreNigeria: FIRS publishes Income Tax (CbC Reporting) regulations
The Federal Inland Revenue Service (FIRS) has released the Income Tax (Country-by-Country Reporting (CbCR)) Regulations on June 19, 2018. It was published in an official gazette on January 8, 2018. This CbCR Regulations give guidelines to
See MoreUruguay: Parliament passes a bill on the Multilateral Instrument (MLI)
4 June 2018, the Uruguayan parliament passed the Bill for the ratification of the Multilateral Convention to Implement Tax Treaty Related Measures to Prevent Base Erosion and Profit Shifting (MLI). Uruguay signed the MLI on 7 June 2017. The MLI will
See MoreIndia: No international transaction with related party in the absence of an agreement with the AE
Recently, the Mumbai Bench of the Income-tax Appellate Tribunal (the Tribunal) ruled its decision on the transfer pricing (TP) case of Colgate Palmolive (India) Ltd. v. ACIT (ITA No. 6073/Mum/2014 and ITA No. 2778/Mum/2011) in favor of the taxpayer.
See MoreIndia: The expenditure specifically incurred for Indian taxpayers’ market cannot be construed to benefit the AE
On 14 May 2018, the Delhi Bench of the Income-tax Appellate Tribunal ruled its decision on the transfer pricing (TP) case of BMW India Pvt. V. ACIT (ITA No 6160 / Del. / 2014) in favor of the taxpayer. The court held that, expenses that are
See MoreBelgium issues a FAQs on MAP and APA
On 23 May 2018, the Public Federal Service (SPF) of Belgium published a document of FAQ on Mutual Agreement Procedure (MAP) and the Advance Pricing Agreement (APA) procedure. The assessee may also request that the tax due in Belgium is not invoiced
See MoreKazakhstan signs MCAA
On 12 June 2018, Kazakhstan signed the Multilateral Competent Authority Agreement (MCAA) on the automatic exchange of Country-by-Country (CbC) reports. Kazakhstan has not yet activated the CbC MCAA in accordance with OECD’s
See MoreAustralia updates international dealings schedule for 2018 tax year
The Australian Taxation Office (ATO) has released the 2018 International dealings schedule (IDS) and their instructions for 2018 tax years. The IDS must be lodged by businesses that provide a response at the trigger questions of the relevant
See MoreIreland: New guidelines on TP compliance
On May 28, Irish Tax and Customs updated Tax and Duty Manual Part 35A-01-01 to set out the government’s approach to monitoring compliance with transfer pricing legislation contained in Part 35A of the Taxes Consolidation Act 1997. The new
See MoreBangladesh: Income Tax Proposal in Fiscal Budget 2018-2019
Finance Minister Mr. AMA Muhith presented the FY2018-19 national budget to parliament on 7th June 2018. Except for a minor downward tweaking of the corporate tax rate, and some small increases in tobacco taxation and supplementary import duties, no
See MoreGermany: The CJEU decision permits deviations from the arm’s length principle
On 31 May 2018, the Court of Justice of the European Union (CJEU) issued its decision in the case of: C-382/16 Hornbach-Baumarkt that a parent company’s position as a shareholder of a non-resident company may be taken into account in
See More