Norway: 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
See MoreIndia: CBDT amends rules to calculate interest income relating to Secondary Adjustments
On 30 September 2019, the Central Board of Direct Taxes (CBDT) has amended rule 10CB which provide for computation of interest income relating to secondary adjustments. The changes remove anomalies and clarify the compliance and computational
See MoreZambia presents the budget for 2020
On 27 September 2019, the Minister of Finance (MOF) presented the budget for 2020 to the National Assembly. Under the budget the following important amendments to the Income Tax Act will take effect from 1 January 2020: Corporate tax
See MoreDenmark deposits ratification instrument for MLI
On 30 September 2019, Denmark deposited its ratification instrument for the Multilateral Convention to Implement Tax Treaty Related Measures (MLI) to Prevent Base Erosion and Profit Shifting. The MLI is designed to allow countries to swiftly add to
See MoreColombia: DIAN issues resolution on MAP
On 13 August 2019, the Colombian National Tax Authority (Dirección de Impuestos y Aduanas Nacionales, DIAN) has published Resolution No. 000053 in the official gazette which establishes Mutual Agreement Procedure (MAP) to avoid double taxation and
See MoreIndia: The new Finance Act modifies the Transfer pricing law
On 5 July 2019, the Minister of Finance presented the Finance (No.2) Act for the financial year 2019-20. The act changes the following transfer pricing rules: Documentations requirements: Under the new amendments, constituent entity of an
See MoreMalta: Commissioner for revenue issues updated MAP guidelines
Earlier the month of June 2019, the Maltese Commissioner for Revenue issued guidance under the provisions of article 96(2) of the Income Tax Act, Chapter 123 of the Laws of Malta (the ‘ITA’) on the use of Mutual Agreement Procedure
See MoreRussia proposes Transfer Pricing and MAP-related changes
The Russian Ministry of Finance has proposed some transfer pricing amendments (Draft legislation No. 720839-7) and submitted them to the State Duma for approval (preliminary examination of the draft law submitted to the State Duma). The draft law
See MoreIndonesia: MoF publishes new guidance on MAP
On 26 April 2019, the Minister of Finance (MoF) issued a new provision on the Mutual Agreement Procedure (MAP) with Regulation No. 49 / PMK.03 / 2019 (PMK-49). PMK-49 is effective from 26 April 2019 and repeals MoF Regulation No. 240 / PMK.03 /
See MoreNigeria: FIRS issues guidance on MAP
On 21 February 2019, Nigeria’s Federal Inland Revenue Services (FIRS) has issued guidelines on Mutual Agreement Procedure (MAP). The guidelines prescribe information regarding eligibility for MAP, access to MAP, overview of the MAP request
See MoreRussia: Finance Ministry publishes Guidance on MAP
On 30 January 2019, the Russian Ministry of Finance published on its official website a guidelines on the mutual agreement procedure (MAP) provided for in double taxation agreements. The guideline contains recommendations for the initiation and
See MoreMexico: SAT publishes the Miscellaneous Fiscal Resolution for 2018
On 30 November 2018, the Tax Administration Service (SAT) published in its portal the "Fourth of Modifications to the Miscellaneous Fiscal Resolution for 2018" and its annexes. Modifications to the value of operations with related parties within the
See MoreMexico publishes the Fourth Resolution of Modifications to the Miscellaneous Fiscal Resolution for 2018
On 30 November 2018, the Fourth Resolution of Modifications to the Miscellaneous Fiscal Resolution for 2018 and Annexes 1, 1-A, 3, 7, 11 and 23 were published in the Official Gazette. Among others the modification added as a criterion in terms of
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