Bulgaria: Parliament accepts tax loss carry forward for CFC
The Parliament recently approved tax loss carry forward rules for controlled foreign companies (CFC). It was stated that the losses may be carried forward for up to five years and should be applied to tax losses incurred after December 31,
See MoreGermany gazettes a law implementing EU directive on cross-border tax planning arrangements
On 30 December 2019, the German Official Gazette published a law implementing EU directive on reporting requirements for cross-border tax planning arrangements. The directive commonly referred to as DAC 6 which require the taxpayers and
See MoreFinland: President sign the law to implement the EU directive on hybrid mismatch rules
On 30 December 2019, the President of Finland signed the Law 1567/2019 that provides for the implementation of the hybrid mismatch rules of the Anti-Tax Avoidance Directive, as amended by Council Directive (EU) 2017/952 (ATAD2). The hybrid
See MoreMalta publishes Regulation to implement DAC6 reporting requirements
On 17 December 2019, Malta published Cooperation with Other Jurisdictions on Tax Matters (Amendment) Regulations 2019 through Legal Notice 342 of 2019. The Amendments transpose the provisions of Council Directive 2018/822 of 25 May 2018 amending
See MoreDenmark: MLI enters into force
On 1 January 2020, the Multilateral Convention to Implement Tax Treaty Related Measures to Prevent Base Erosion and Profit Shifting (MLI) entered into force for Denmark. On 30 September 2019, Denmark deposited its instrument of ratification for the
See MoreFinland adopts EU directive on cross-border tax planning arrangements
On 30 December 2019, Finnish President approved the Law 1559/2019 for the implementation of Council Directive (EU) 2018/822 of 25 May 2018 (DAC6) on reporting requirements for cross-border tax planning arrangements. Under DAC6, taxpayers
See MoreAustria releases digital services tax guide
On 20 December 2019, Finance Ministry published guide regarding digital service tax. Under the guide, 5% tax will be applicable for advertisements on a digital interface. Accordingly, this guide helps to know of how to submit or payment digital
See MoreLuxembourg 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 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 MoreLithuania: Parliament approves higher corporate income tax for banks
On 18 December 2019, Lithuanian lawmakers passed higher corporate tax for banks from January 2020. Higher corporate tax rate of 20% will apply to bank profit exceeding 2 million euros. Banks, like other legal entities in Lithuania, are now taxed at
See MoreDTA between Estonia and Hong Kong enters into force
On 18 December 2019, the Double Taxation Agreement (DTA) between Estonia and Hong Kong was entered into force and applies from 1 January 2020 for Estonia and from 1 April 2020 for Hong Kong. The DTA contains Dividends rate 0% if the beneficial
See MoreDTA between Czech Republic and Korea (Rep.) enters into force
On 20 December 2019, the Double Taxation Agreement (DTA) between Czech Republic and Korea (Rep.) was entered into force and applies from 1 January 2020. From this date, the new DTA replaces the former DTA of 1992. The DTA contains Dividends
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 MoreLuxembourg: Parliament approves budget law for 2020
On 19 December 2019, Luxembourg Parliament approved 2020 budget law which was presented by Luxembourg’s Finance Minister on 14 October 2019. According to the budget law, the advance tax rulings issued by the Luxembourg tax authorities before 1
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 MoreNetherlands approves Tax Plan 2020
The Dutch Ministry of Finance has announced that the Senate has approved the 2020 Tax Plan on 17 December 2019; however the Dutch Government published the 2020 budget proposals on 17 September 2019. Some of the key changes from 1 January 2020
See MoreDTA between Bangladesh and Czech Republic signs
On 11 December 2019, the Double Taxation Agreement (DTA) between Bangladesh and Czech Republic was signed in Prague. The DTA contains Dividends rate 10% for at least 25% capital holding; otherwise 15%, Interest rate 10%, and Royalties rate
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