Cyprus: House of Representatives approves law for ATAD Interest Limitation, CFC, and GAAR Rules
On 5 April 2019, the Cyprus House of Representatives passed a law that addresses certain provisions of the EU anti-tax avoidance directive (ATAD 1) particularly the interest limitation rule, a general anti-avoidance rule (GAAR) and controlled
See MorePoland: Government publishes draft bill introducing simplified APA procedure
On 22 March 2019, Poland’s legislative centre published a draft bill that addresses dispute resolution of double taxation issues and advance pricing agreements (APAs). Under this taxpayers will be benefited from the new procedure on Simplified
See MoreGermany updates Guidance on CbC reporting requirements
The German Ministry of Finance issued an updated version of the Application Decree on the General Tax Code on 5 April 2019. The updated version provides for guidance on the application of section 138a of the General Tax Code (GTC) by the tax
See MoreDenmark approves deadlines for preparing, submitting transfer pricing documentation
Recently, the Danish parliament adopted an important amendment of the Tax Control Act (L 13 Forslag til Skattekontrollov of October 4, 2017) that is in force from January 1, 2019 with regard to transfer pricing documentation. The purpose of the
See MoreCzech Republic releases law Implementing ATAD with others changes
On 27 March 2019, the Czech Republic released the Law of 12 March 2019, which includes the introduction of measures to comply with the EU Anti-Tax Avoidance Directive (ATAD). The law usually enters into force on 1 April 2019. However, the taxation
See MoreCyprus publishes a draft law implementing EU directive on cross-border tax arrangements
On 19 March 2019, the Cypriot Ministry of Finance (MoF) published a draft law implementing EU Directive 2018/822/EU of 25 May 2018 on the mandatory disclosure and exchange of cross-border tax arrangements into national legislation. The Directive
See MoreGreece: Tax administration issues circulars on CIT and Dividend tax rate cut
On 21 March 2019, the Public Revenue Authority issued two circulars (E.2046 / 2019 and E.2047 / 2019) for reducing corporate tax rates and dividend tax rates. These circulars are summarized below: Circular E.2046: This circular confirms that
See MoreCzech Republic published law including CFC rules
On 27 March 2019, the Czech Republic released the Law of 12 March 2019, which includes CFC rules among other changes. A foreign company or permanent establishment will be considered controlled foreign company (CFC) for tax purpose if the Czech
See MoreCosta Rica publishes amending resolution regarding CbC reporting
On 18 March 2019, the Government of Costa Rica published Resolution No DGT-R-008-2019 in the Official Gazette. The resolution amends Resolution DGT-R-001-2018, which regulated the information that companies headquartered in Costa Rica have to
See MoreBelgium approves MLI
On 21March 2019, the Parliament of Belgium approved the law ratifying of the Multilateral Convention to implement double taxation avoidance agreement related measures to prevent Base Erosion and Profit Shifting (BEPS). After the
See MoreLuxembourg: Finance Minister presents draft budget law for 2019
On 5 March 2019, the Luxembourg Minister of Finance, Pierre Gramegna, presented to the Chamber of Deputies the draft budget law 2019 together with the draft multi-annual financial planning, for the 2019-2022 period to the Chamber of Deputies. The
See MoreFinland: Tax administration publishes guidelines on interest limitation rules
On 7 March 2019, the Finnish tax administration published new guidelines on the rules on interest deduction restrictions, which were amended to comply with EU Anti-Tax Avoidance Directive (ATAD), and contained a general 25% EBITDA interest deduction
See MoreIreland updates R&D tax credit
On 6 March 2019, Irish Revenue releasedTax and Duty Manual Part 29-02-03, which includes the Research and Development Tax Credit guidelines. Sections 766, 766A and 766B of the Taxes Consolidation Act (TCA) 1997 (the Act) and the Taxes
See MoreIreland: Tax relief for new start-up companies
On 1 March 2019, Irish Revenue released Tax and Duty Manual Part 15-03-03 that has been updated to reflect the amendment made in Finance Act 2018 which extended the relief for start-up companies under section 486C of the Taxes
See MoreSlovak Republic: New proposal to revise R&D tax regime
On 21 February 2019, the government of Slovak Republic proposed to amend the research and development (R&D) tax regime. The proposed amendment would increase the allowable deduction with qualifying R&D expenditures. According to proposal,
See MoreLuxembourg: Tax Authority clarifies the new Permanent Establishment definition
On 22 February 2019, Luxembourg tax authorities issued a new circular (No.19) that clarifies recently added the new Permanent Establishment (PE) definition as set forth in article 16(5) of the Tax Adaptation Law (StAnpG). Under the new paragraph,
See MoreSlovak Republic: New guidelines for TP documentation requirements
The Ministry of Finance of the Slovak Republic issued new guidelines no. MF/019153/2018-724 (MF SR Guidelines 2018) on content of the transfer pricing (TP) documentation was issued in December 2018 replacing the Guidelines no. MF/014283/2016-724 (MF
See MoreIreland: Public consultation on new transfer pricing regime
On 18 February 2019, Department of Finance of Ireland released the public consultation document to update transfer pricing regime, with an effective date of 1 January 2020. The consultation looks for feedback on a number of aspects of existing
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