Bulgaria modifies the CFC Rules
The recently published Bulgarian Law amending and supplementing the Tax and Social Security Act includes some modifications and explanations of the rules for Controlled Foreign Companies (CFC), which were introduced with effect from 1 January 2019,
See MoreLuxembourg: Government submits EU Anti-Tax Avoidance Directive to Parliament
On 9 August 2019, Luxembourg Government submits draft law to the Parliament for the execution of the expanded hybrid mismatch rules of the European Union (EU) Anti-tax Avoidance Directive as amended (ATAD2). The draft law aims at broadening the
See MoreBulgaria publishes new mandatory TP documentation requirements
On 13 August 2019, amendments to the Tax and Social Security Procedure Code (TSSPC) were published in the State Gazette. The law introduced the mandatory new transfer pricing (TP) documentation requirements in Bulgaria. Documentation
See MoreHungary publishes legislation implementing EU directive on hybrid mismatch rules
On 23 July 2019, Hungary published a legislation through an official gazette that provides for the implementation of exit tax and hybrid mismatch rules of the EU Anti-Tax Avoidance Directive (ATAD). On 12 July 2019, the Hungarian legislator passed
See MoreLithuania implements EU Directive on mandatory disclosure rules
On 30 July 2019, the President signed the primary legislation implementing the European Union (EU) Directive on the mandatory disclosure and exchange of reportable cross-border tax arrangements (referred to as DAC6 or the Directive) into
See MoreBelgium: CbC report corrections guidelines
On 30 July 2019, the Federal Public Service Finance of Belgium issued a notice on its transfer pricing - BEPS 13 guidance page that the MyMinfin Portal is now available for the submission of Country-by-Country (CbC) report
See MoreBulgaria approves CbC Exchange Agreements with U.S.
On 10 July 2019, Bulgaria's Council of Ministers approved two agreements with the United States allowing for the automatic exchange of country-by-country reports. The CbC report is one element of the three-tiered standardized approach to transfer
See MoreBulgaria approves new mandatory TP documentation requirements
On 31 July 2019, the National Assembly approved at second (final) reading amendments to the Tax and Social Security Procedure Code (TSSPC), which introduced the new transfer pricing (TP) documentation requirements. New rules for TP
See MoreFrance: President signs new Law of digital services tax
The new Law No. 2019-759 has been published on July 25, 2019, in the Official Gazette, which introduces Digital Services Tax (DST). It was signed by the French President, Emmanuel Macron, on July 24, 2019. This new Law also modifies the downward
See MoreLuxembourg: DTA with Kosovo enters into force
On 23 July 2019, the Double Taxation Agreement (DTA) between Kosovo and Luxembourg was entered into force and applies from 1 January 2020. The agreement was signed on 8 December 2017. The agreement contains Dividends rate 0% for at least 10%
See MoreDTA between Luxembourg and Uzbekistan enters into force
On 26 July 2019, the amending protocol to the Double Taxation Agreement (DTA) between Luxembourg and Uzbekistan was entered into force and applies from 1 January 2020. The agreement was signed by Luxembourg Minister of Finance Pierre Gramegna and
See MoreLuxembourg: MLI enters into force
On 1 August 2019, the multilateral convention to implement tax treaty related measures to prevent Base Erosion and Profit Shifting (Multilateral Instrument or MLI) entered into force in respect of Luxembourg. MLI provisions that affect withholding
See MoreLithuania implements EU Directive on Dispute Resolution
On 11 July 2019, Lithuania has published Law No. XIII-2310 in the Official Gazette, which includes measures for the implementation Council Directive (EU) 2017/1852 of 10 October 2017. This includes rules to ensure effective resolution of
See MoreMalta updates NID Guidelines
On 11 July 2019, the Maltese Commissioner for Revenue has issued updated guidelines regarding the Notional Interest Deduction (NID) rules. The updated guidelines explains a number of factors including the determination of the reference rate, the
See MoreGreece: Government announces a wide range of Tax Cuts
Following the recent victory in the countries general election, the new Greek Prime Minister has announced that the government wants to introduce a wide range of tax cuts in order to boost the economy after several years of lack of funding and
See MoreAustria implements EU Directive on Dispute Resolution
On 22 July 2019, Austria has published the EU Financial Adjustment Act 2019 in the Official Gazette, which includes measures for the implementation Council Directive (EU) 2017/1852 of 10 October 2017. This includes rules to ensure effective
See MoreHungary: Parliament passes budget for 2020
On 12 July 2019, the Hungarian Lawmakers approved the 2020 budget. The budget targets revenue of 21,426.0 billion forints and expenditures of 21,793.0 billion forints, producing a deficit of 367.0 billion forints. Highlighted features of the
See MorePortugal approves amendments to the TP rules
On 19 July 2019, the Portuguese parliament approved Law No. 180/2019, which includes amendments to the country's transfer pricing (TP) rules. The new law changes the following rules: Abolishing the hierarchy in the selection of the transfer
See More