Luxembourg: 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 MoreIreland introduces EU Directive on Dispute Resolution
Ireland has issued Statutory Instrument (S.I.) No. 306/2019 of 5 July 2019, that includes regulations for the purpose of giving effect to Council Directive (EU) 2017/1852 of 10 October 2017 on dispute resolution. The Directive
See MoreMalta introduces EU Directive on Dispute Resolution
On 12 July 2019, Malta has published regulations in the Official Gazette implementing Directive of European Union Council Directive (EU) 2017/1852 of 10 October 2017 on tax dispute resolution mechanisms into domestic law. The regulations came
See MoreLatvia: President signs a Law to ratify BEPS MLI
On 22 July 2019, Latvian President Egils Levits has signed a law for ratification of the Multilateral Convention to Implement Tax Treaty Related Measures to Prevent BEPS (MLI). Latvia must now deposit its ratification instrument to
See MoreHungary: Parliament approves exit tax and hybrid mismatch rule in line with ATAD
On 12 July 2019, the Hungarian legislator passed an anti-tax avoidance rule for the implementation exit tax and hybrid mismatch rules in line with the EU Anti-Tax Avoidance Directive (ATAD). The exit tax rules would apply from 1 January 2020
See MoreLuxembourg: Tax administration updates its CbC reporting guidance page
On 16 July 1019, the Luxembourg tax administration released its CbC reporting guidance page with new updates, including a new user manual for the MyGuichet e-filing system for submitting CbC reports and a new XSD schema (XML). Under the new manual
See MoreIreland introduces new Guidance on CFC rules
On 22 July 2019, Ireland has published a new Tax and Duty Manual, Part 35b-01-01 in respect of the Controlled Foreign Company (CFC) rules, that were introduced by Finance Act 2018 and take effect from 1 January 2019. The manual provides an
See MoreDenmark publishes a notice regarding transfer pricing documentation
On 12 July 2019, the Danish Tax Authority has published a notice (SKM2019.374.SKTST) which establishes a new practice for the importance of whether a transfer pricing documentation in its entirety is available at the time of tax return. The
See MoreLatvia publishes regulations for low value-adding intra-group services
On 9 July 2019, Latvia published Cabinet Regulations No. 324 of 9 July 2019 in the Official Gazette addressing simplified transfer pricing provisions for intra-group low value-added services. The Regulation provides that the general
See MoreDenmark implements EU dispute resolution directive
The Act implementing Council Directive (EU) 2017/1852 of 10 October 2017 in Denmark entered into force on 30 June 2019. The Directive contains provisions on the effective resolution of disputes concerning the interpretation and application of
See MoreGreece: Tax authority clarifies the limitation period for the late filing of tax return
On 1 July 2019, the tax authority published the Circular E.2123 explaining the application of the limitation period in the event of late filing of a tax return. The new Circular amends Circular 1165/2018 in relation to the limitation period of 15
See MoreFrance issues new guidelines for GAAR
On 3 July 2019, the tax authorities published a guidelines regarding the new general anti-abuse rule (GAAR). The new GAAR, which applies from 1 January 2019, targets provisions that focus on tax-driven abuses of law. According to the guidance,
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