Malta amends EU ATAD Implementation Regulations

23 February, 2020

Recently, Malta has published Legal Notice No. 29 of 2020 in the Official Gazette amending Regulation 10 of the EU Anti-Tax Avoidance Directives (ATAD) Implementation Regulations. The Regulation states that the reverse hybrid rules will apply from

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Poland: Council of Ministers submit ATAD2 hybrid mismatch measures to parliament

20 February, 2020

On 5 February 2020, Poland's Council of Ministers submitted some tax measures in parliament including the hybrid mismatch measures of the EU Anti-Tax Avoidance Directive as amended (ATAD2). ATAD2 would address tax avoidance through hybrid

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EU: Four more jurisdictions added to blacklist

19 February, 2020

On 18 February 2020 the European Union (EU) added Panama, Palau, the Seychelles and the Cayman Islands to its blacklist of non-cooperative jurisdictions for tax purposes. The decision was taken at the meeting of the EU economic and finance

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Poland: Administrative Court allows expenditure on intra-group services

19 February, 2020

On 6 February 2020, Polish Administrative Court (the “Court”) issued its decision on a transfer pricing case regarding Poland vs Shared Service Center. A shared service center (SSC) in Poland both provided intra-group services to the group

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Luxembourg amends draft law implementing DAC6

18 February, 2020

On 14 February 2020, Luxembourg published a revised version of the draft law 7465 amending the original provisions on the professional privilege exemption. Luxembourg Government submitted the draft law on 8 August 2019 which has not been passed

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Czech Republic: President signs a Law to ratify BEPS MLI

16 February, 2020

On 13 February 2020, the President signed a law for ratification of the Multilateral Convention to Implement Tax Treaty Related Measures to Prevent BEPS (MLI). On 28 November 2019, the Chamber of Deputies approved the ratification of BEPS MLI. The

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Portugal publishes revised version of draft legislation on DAC6

14 February, 2020

On 31 January 2020, the Government of Portugal published revised draft legislation to implement the European Union (EU) Directive on the mandatory disclosure and exchange of cross-border tax arrangements (DAC6). The final law is expected to be

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Greece: Public Revenue Authority publishes a Circular for clarifying about dividend tax rate

11 February, 2020

The Public Revenue Authority (AADE) published Circular E. 2012 of 30 January 2020, which provides guidance on reducing the withholding tax (WHT) rate from 10% to 5% under the provisions of article 24 of Law 4646/2019. This also states that this

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Sweden: Government submits final draft law to implement DAC6 to Parliament

10 February, 2020

On 4 February 2020, the Swedish Government has submitted final draft law on implementation of Council Directive (EU) 2018/822 of 25 May 2018 (DAC6) on reportable cross-border tax planning arrangements (DAC6) to Parliament. The Ministry of Finance

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Romania enacts EU mandatory disclosure regime (DAC6)

10 February, 2020

On 28 January 2020, the Government of Romania has published Ordinance no. 5 of 28 January 2020 in the Official Gazette for the implementation of Council Directive (EU) 2018/822 of 25 May 2018 (DAC6) on reportable cross-border tax planning

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Bulgaria: Finance Ministry publishes an Order to incentive purposes

10 February, 2020

On 30 January 2020, the Finance Ministry published Order No. ZMF-89 of 30 January 2020 regarding lists the municipalities with unemployment rates, which is used to provide tax incentives for manufacturing companies including complete corporate

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Ireland: Tax Revenue publishes e-Brief No. 029/20 on “main benefit test” under DAC6 legislation

09 February, 2020

On 4 February 2020, the Tax Revenue published a manual, entitled “e-Brief No. 029/20”, relating to the “main benefit test. The manual has been updated to include a reference to the EU mandatory disclosure regime (DAC6), which comes into force

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Italy issues updated tax return forms with instructions for 2020

08 February, 2020

On 31 January 2020, the Italian Revenue Agency released instructions on procedure to comply with income tax return filing obligations during 2020. The Italian tax authority said the following changes have been incorporated into returns this year:

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Portugal: Draft bill to implement ATAD1 and ATAD2

08 February, 2020

On 30 January 2020, a draft bill was presented to the Parliament for the execution of the hybrid mismatch rules of the EU Anti-Tax Avoidance Directive and the Directive as amended (ATAD1 and ATAD2). This consists of measures to counter hybrid

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France: Tax authority publishes guidelines on the new provisions on abuse of law

06 February, 2020

On 31 January 2020, the tax authority published guidelines regarding the application of the new general anti-abuse rules (GAAR). This guide provides an extension of Article 6 of the EU Anti-Tax Avoidance Directive 2016/1164. It may also apply in

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UK notifies the WTO of withdrawal from the European Union

04 February, 2020

A communication from the UK on 1 February 2020 (WT/GC/206) has set out detail on the implications for the World Trade Organisation (WTO) of its departure from the European Union (EU). The communication notifies the WTO that the UK ceased to be a

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Cyprus deposits MLI ratification instrument

04 February, 2020

The OECD announced that Cyprus deposited its instrument of ratification for the Multilateral Convention to Implement Tax Treaty Related Measures to Prevent Base Erosion and Profit Shifting (MLI) on 23 January 2020. Cyprus also submitted its MLI

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Luxembourg updates list of jurisdictions for exchanging CbC reports

03 February, 2020

On 27 January 2020, Luxembourg Ministry of Finance published Grand-Ducal Regulation of 24 January 2020 amending Grand-Ducal Regulation of 13 February 2018. The Regulation updates the list of jurisdictions for exchanging Country-by-Country (CbC)

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