Luxembourg implements EU ATAD 2 anti-hybrid measures
On 19 December 2019, the Luxembourg Parliament approved draft law implementing EU Anti-Tax Avoidance Directive (2017/952) (ATAD 2) into Luxembourg domestic law. ATAD 2 amends the EU Directive 2016/1164 which applies to mismatches between EU member
See MoreVietnam: MOF publishes draft Decree on deductible interest expenses
On 12 December 2019, the Vietnam Ministry of Finance (MOF) has published the draft Decree amending and supplementing Clause 3, Article 8 of Decree 20/2017/ND-CP to regulated approach on determining the deductibility for interest expense for
See MoreQatar publishes new regulations to amend income tax law
On 11 December 2019, Qatar published Executive regulations 39/2019 in the Official Gazette, introduced new Income Tax Law No. 24 of 2018. The new regulations are generally effective from 12 December 2019. Key features of the new regulations
See MoreOECD: Peer review reports on exchange of information on tax rulings
On 23 December 2019 the OECD released the 2018 peer review reports on the exchange of information on tax rulings. The reports cover implementation of the minimum standard under action 5 of the OECD action plan on base erosion and profit shifting
See MoreCosta Rica: Ministry of Finance publishes draft resolution on APA guidelines
In December 2019, the Costa Rican Ministry of Finance released a draft resolution regarding the procedures for processing advance pricing agreements (APAs). The draft guidelines state that APA applications would need to be addressed to the
See MoreArgentina: Tax Authority publishes Law 27541 for implementing tax reform 2020
On 23rd December 2019, Argentina published Law 27541 regarding Social Solidarity and Productive Reactivation in the Official Gazette, which contains measures on corporate income tax, personal income tax, dividend withholding tax etc. The Law was
See MoreGermany gazettes a law implementing EU directive on tax dispute resolution mechanism
On 12 December 2019, the German Official Gazette published a law implementing EU directive on tax dispute resolution providing a uniform mechanism to address tax treaty disputes among EU member states that meets the BEPS Action 14 minimum
See MoreGermany: Federal Ministry of Finance publishes a draft law with significant changes to TP rules
On 10 December 2019, Germany published a draft law implementing EU anti-tax avoidance directive. The Draft Law includes significant changes to the German transfer pricing rules. The following proposed changes have been taken place under the
See MoreFrance: Parliament adopts Finance Bill 2020
On 19 December 2019, The French parliament adopted the Finance Bill for the year 2020 but it is still require to review by the constitutional court. Provisions include in the Finance Bill are given below: Corporate Tax rate The draft Finance
See MoreEstonia: President signs a Law to ratify BEPS MLI
On 13 December 2019, Estonian President has signed a law for ratification of the Multilateral Convention to Implement Tax Treaty Related Measures to Prevent BEPS (MLI). On 4 December 2019, the Parliament ratified the MLI. Estonia must now deposit
See MoreUkraine: SFS explains about foreign exchange differences for transfer pricing purposes
Recently, the Ukraine State Fiscal Service (SFS) has explained about treatment of foreign exchange differences if controlled transactions meet the transfer pricing thresholds. Transactions are classified as controlled transactions if the annual
See MoreSOUTH KOREA: National Assembly approves Multilateral Instrument (MLI)
On 10 December 2019, South Korea's National Assembly has approved multilateral convention to implement tax treaty related measures to prevent Base Erosion and Profit Shifting (MLI). After the ratification process, South Korea will need to deposit
See MoreArgentina: AFIP declares further extensions to TP filing deadlines
On 16 December 2019, the Tax Authority (AFIP) announced further extensions to timeline to transfer pricing (TP) filing returns for the financial years ending on December 31, 2018. Previously, under General Resolution 4538/2019 of 30 July 2019
See MoreIndonesia: Tax dispute resolution peer review report
On 28 November 2019 the OECD published a stage 1 peer review report commenting on Indonesia’s compliance with the minimum standard on tax dispute resolution under Action 14 of the project on base erosion and profit shifting (BEPS). The
See MoreMexico implements economic package 2020
On 9 December 2019, Mexico has published a decree to implement economic package 2020 which was approved by Mexican Congress on 30 October 2019. This Decree will enter into force on January 1, 2020. The economic package consists of the following
See MoreSlovenia publishes guidance on the latest amendments to the CITA
On 2 December 2019, the tax authority has published guidance regarding the latest amendments to the Corporate Income Tax Act (CITA). The guidance also provides for a detailed description about implementation of the hybrid mismatch rules of the EU
See MoreSaudi Arabia introduces E-Service for CbC reporting
Recently, the General Authority of Zakat and Tax (GAZT) of Saudi Arabia have introduced E-Service for country-by-country (CbC) reporting. As per the transfer pricing Bylaws, Saudi Arabian taxpayers that are members of an MNE Group with consolidated
See MoreSerbia: Parliament amends the corporate income tax law including CbCR obligations
On 6 December 2019, the Serbian Parliament passed the legislation that amends the corporate income tax law including requirements for country-by-country (CbC) reporting of controlled transactions within a corporate group. The Law is published in
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