France: Government publishes transposition order of DAC6
On October 22, 2019, Government published a French Ordinance No. 2019-1068 of 21 October 2019, regarding the Automatic and Compulsory Exchange of Information in the Field of Taxation in Relation to Cross-Border Devices for Reporting. The EU
See MoreUkraine: STS clarifies on controlled transactions report
On 18 September 2019, the State Tax Service (STS) of Ukraine explained about the procedure to file report on controlled transactions for transfer pricing purposes. According to the procedure, representative office that does not meet the conditions
See MoreSlovenia implements the mandatory disclosure rules
On 28 May 2019, the Slovenian Parliament has approved the EU Directive on the mandatory disclosure and exchange of cross-border tax arrangements (DAC6). The final Slovenian Mandatory Disclosure Rules legislation is significantly aligned to the
See MoreUkraine issues guidance on transactions between non-resident and its representative offices
On 16 August 2019, the Ministry of Finance issued Order No. 345 providing guidelines on transfer pricing arrangements for transactions between non-residents and their representative offices and permanent establishments in Ukraine. The Order
See MoreCosta Rica: Tax authority issues guidance on transfer pricing rules
On 26 June 2019, Costa Rican tax authority published the Resolution N° 41818-H in the Official Gazette that changes Income Tax Law regulation including transfer pricing obligations. The new Regulation defines persons as related persons who are
See MoreUkraine: SFS clarifies treatment of controlled transactions with Bulgaria
On 20 June 2019, the Ukraine State Fiscal Service published a guidance letter No. 2826/6/99-99-15-02-02-15/IPC defining the treatment of transactions with residents of tax Bulgaria, which was removed from the Cabinet tax haven list in April
See MoreArgentina: Tax ruling on BEPS Action 5 minimum standard
On 30 May 2019, the Argentine tax authority published General Resolution No. 4497 (GR 4497/2019) in the official gazette amending the binding ruling (as established by Article 4 of Law No. 11,683) regulations, which adapts the Argentine tax
See MoreUkraine: SFS clarifies controlled transactions between a non-resident and its PE in Ukraine
On 19 April 2019, the State Fiscal Service (SFS) of Ukraine published a guidance letter 1723/6/99-99-15-02-02-15/IPK on the treatment of transactions between a non-resident and its permanent establishment (PE) in Ukraine as controlled for transfer
See MoreUkraine: SFS issues letter on transfer pricing rules to salaries paid to non-residents
On 29 March 2019, the State Fiscal Service (SFS) of Ukraine issued letter 1358/6/99-99-15-02-15/ІPK on the treatment of salary payments to non-resident persons as controlled for transfer price purposes. The letter states that such payments
See MoreCyprus publishes a draft law implementing EU directive on cross-border tax arrangements
On 19 March 2019, the Cypriot Ministry of Finance (MoF) published a draft law implementing EU Directive 2018/822/EU of 25 May 2018 on the mandatory disclosure and exchange of cross-border tax arrangements into national legislation. The Directive
See MoreIreland: Public consultation on new transfer pricing regime
On 18 February 2019, Department of Finance of Ireland released the public consultation document to update transfer pricing regime, with an effective date of 1 January 2020. The consultation looks for feedback on a number of aspects of existing
See MoreFinland gazettes the law implementing the controlled foreign company (CFC) rules
On 31 December 2018, a law was published on the implementation of CFC rules in line with EU directive (EU) 2016/1164 (2016) as adopted by the parliament which is incorporated into Finnish legislation as a Law No. 1364/2018. The law introduced
See MoreMalaysia: Parliament passes Finance bill 2018 (Budget 2019)
On 10 December 2018, the House of Representatives passed the Finance Bill 2018 which was published in the Federal Gazette on 27 December 2018. The key changes of Finance Bill 2018 are summarized below: Corporate Tax Changes The limitation
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 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 MorePoland: President signed an act including amendment of TP measures effective in 2019
On 14 November 2018, President of Poland signed an act including amendment of transfer pricing measures effective in 2019. The new laws repeal the Article 9a of the CIT Act regarding transfer pricing, which is being replaced by Chapter 1a,
See MoreThailand enacts Transfer pricing law
On 21 November 2018, Thailand's new transfer pricing law was enacted and published in the Official Gazette and will be effective from 1 January 2019, which was approved by the National Legislative Assembly in 27 September 2018. Tax assessment
See MoreFinland: Ministry of Finance submits a bill on changes to CFC rules to Parliament
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 direct or indirect
See More