Puerto Rico amends income tax law for deduction of intercompany charges
Recently, Puerto Rico has amended Section 1033.17(a)(17) of the Puerto Rican Internal Revenue Code of 2011 regarding intercompany expense allocation. Previously there was a disallowance of 51% of intercompany charges. According to the amendment,
See MoreIreland: Revenue updates MAP guidance for BEPS MLI
The Revenue has recently released eBrief No. 223/19 entitled Tax and Duty Manual Part 35-02-08 on amended MAP guidelines to implement for the ratification of the multilateral convention to implement tax treaty related measures to prevent BEPS
See MoreDTA between Ecuador and Japan enters into force
On 28 December 2019, the Double Taxation Agreement (DTA) between Ecuador and Japan was entered into force and applies from 1 January 2020. The DTA contains Dividends rate 5%, Interest rate 10%, and Royalties rate
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 MoreUkraine: MLI enters into force
On 1 December 2019, the Multilateral Convention to Implement Tax Treaty Related Measures to Prevent Base Erosion and Profit Shifting (MLI) entered into force with respect to the Ukraine. On 8 August 2019, Ukraine deposited its instrument of
See MoreOman signs MLI to implement tax treaty related BEPS measures
On 26 November 2019, Oman signed the Multilateral Convention to Implement Tax Treaty Related Measures to Prevent Base Erosion and Profit Shifting (MLI). Oman also signed the Multilateral Convention on Mutual Administrative Assistance in Tax
See MoreKenya signs BEPS MLI on multinational group taxation
On 26 November 2019, Kenya signed the Multilateral Convention to Implement Tax Treaty Related Measures to Prevent Base Erosion and Profit Shifting (MLI). The provisional list of reservations and notifications to the MLI (i.e. its MLI position)
See MoreCzech Republic: Chamber of Deputies approves ratification of BEPS MLI
On 28 November 2019, the Chamber of Deputies approved the ratification of the multilateral convention to implement tax treaty related measures to prevent BEPS (MLI). The Czech Republic now has to deposit its instrument of ratification in order to
See MoreCosta Rica ratifies the BEPS MLI
On 12 November 2019, Costa Rica enacted Law No. 9751 by publishing the official gazette No.215. The law ratifies the Multilateral Instrument to Implement Tax Treaty Related Measures to Prevent BEPS (the MLI). Costa Rica must submit the ratified
See MoreTaiwan: MOF clarifies the procedures for one-time transfer pricing adjustments
On 15 November 2019, the Ministry of Finance issued a ruling no.10804629000 providing the guidance when multinational enterprises (MNEs) make a one-time transfer pricing adjustment to achieve an arm’s length result. For making one-time
See MoreOECD: Input requested for dispute resolution peer reviews
On 18 November 2019 the OECD invited interested parties to submit input in relation to the tenth batch of dispute resolution peer reviews. Information should be submitted to the OECD by 16 December 2019 using the taxpayer input questionnaire. The
See MorePoland publishes a law implementing EU directive on dispute resolution and new provisions on APAs
On 14 November 2019, Poland published the Law of 26 October 2019 on resolution of disputes over double taxation and the execution of advance pricing agreements (the “Act”), which generally entered into force on 29 November 2019. The law
See MoreNorway: BEPS multilateral instrument (MLI) enters into force
On 1 November 2019, the Multilateral Convention to Implement Tax Treaty Related Measures to Prevent Base Erosion and Profit Shifting (MLI) entered into force for Norway. On 17 July 2019, Norway deposited its instrument of ratification regarding
See MoreBosnia and Herzegovina signs MLI to implement tax treaty related BEPS measures
On 30 October 2019, Bosnia and Herzegovina signed the Multilateral Convention to Implement Tax Treaty Related Measures to Prevent BEPS (MLI). The countries involved in the Inclusive Framework are working towards implementation of the BEPS
See MoreTurkey: Revenue Administration issues guideline on MAP
On 17 October 2019, the Turkish Revenue Administration has released guideline on the mutual agreement procedure (MAP) under double taxation agreement on their website as well as a table of guidance indicating the time limits for each country
See MoreGermany: Federal Tax Court changes perspective on domestic TP adjustments in tax treaty cases
On 27 February 2019, three recently published decisions (IR 51/17, IR / 73/16, and IR 81/17) provided that the German Federal Tax Court (BFH) had changed its opinion on the application of transfer pricing (TP) rules in relation to transfer
See MoreRussia: MLI enters into force
On 1 October 2019, the Multilateral Convention to Implement Tax Treaty Related Measures to Prevent Base Erosion and Profit Shifting (MLI) entered into force with respect to the Russian Federation. On 18 June 2019 the Russian Federation deposited
See MoreRussia enacts legislative changes on Transfer Pricing and MAP
On 29 September 2019, the Russian Government signed a Law no. 325-FZ (Amendments to the Tax Code of the Russian Federation) and published in the Official Gazette. The main amendments relating to transfer pricing are as
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