Portugal: Parliament proposes to implements The Anti-Tax Avoidance Directive
Recently, the Portuguese Government has submitted to Parliament the Bill No.177/XIII introducing changes to the Income Tax Act to implement certain ATAD-1 rules. The bill proposed rules for the limitation of interest deductions and rules for
See MoreSweden: Proposal for the extension of the hybrid match rules submits for comments
On 1 February 2019, the Ministry of Finance has sent a memorandum on referral with a proposal to extend the so-called hybrid rules. The purpose of the rules is to prevent differences in countries legislation being used in cross-border arrangements
See MoreBelgium updates TP reporting penalties
On 8 February 2019, the Belgian Federal Public Service (SPF) Finance published Circular Letter No. 2019/C/14 regarding penalties due if a taxpayer fails to fulfill its transfer pricing (TP) reporting obligations. The Circular Letter is an annex to
See MorePortugal legislates law on automatic exchange of financial information
The Assembly of the Republic of Portugal adopted Legislative Decree 17/2019 on 14 February 2019. The law amends the current implementation of the rules governing the automatic exchange of information in tax matters under Council Directive 2014/107 /
See MorePortugal legislates the Budget Law for 2019
On December 31, 2018, Portugal published 2019 budget law (No.71/2018) in the official gazette and generally applies as from 1 January 2019. The budget law includes changes to income tax law and other taxes. The budget law include the following
See MoreSpain introduces law on digital service tax
On January 25, 2019, a bill on the digital service tax was published in the law sheet of the Spanish legislature. If adopted, it is expected that the bill will be applied in the second half of 2019. The digital services tax would apply to taxpayers
See MoreCroatia: Finance Minister declares related party interest rate for 2019
The Croatian Minister of Finance, referring to National Gazette 118/2018 of 27 December 2018, has declared to reduce the interest rate on loans between related parties from 4.55% to 3.96% per annum. The reduction of so called the arm’s length
See MoreBelgium: Parliament approves new restriction on interest deduction
On 31 January 2019, the parliament of Belgium approved legislation implementing the 30% of Earnings before interest, tax, depreciation and amortization (EBITDA) restriction on interest deduction to 1 January 2019. The restriction is according to the
See MoreItaly: Tax authority releases new corporate tax return forms
On 30 January 2019, Italy’s tax authority issued protocols (No.23599/2019 and No. 23568/2019) approving the new electronic corporate income tax return form and regional tax on productive activities return form to be used for tax year 2018. Forms
See MoreBulgaria: NRA publishes corporate income tax return form for 2018 with barcode
On 4 February 2019, the National Revenue Agency (NRA) published the annual tax return under Art. 92 of the CITA for 2018 with BARCODE on the website of NRA. Detailed instructions for downloading, completing and submitting the statement are added to
See MoreDenmark: Supreme Court rules against Ministry of Taxation in landmark Transfer Pricing case
On 31 January 2019, Denmark's Supreme Court issued its decision on a transfer pricing case regarding Microsoft Denmark ApS (Microsoft Denmark) which is a Danish subsidiary of the United States (US) software company Microsoft Corporation. In its
See MoreFrance: Parliament legislates the Finance Act for 2019
The French Finance Act passed its constitutional review for 2019 on 28 December 2018. This follows the approval of the law by Parliament on 20 December 2018. The main measures of the law are summarized as follows: Corporate Income tax rate:
See MoreEU: Free trade agreement with Japan enters into force
The EU-Japan free trade agreement has been ratified by both parties and enters into force on 1 February 2019. Under the agreement certain goods originating in Japan for import into the EU or originating in the EU for export to Japan may be eligible
See MoreEuropean Commission to launch proceedings against UK over VAT treatment of commodity traders
It is reported that the European Commission is planning to take a case to the European Court of Justice (ECJ) in relation to the value added tax (VAT) treatment of commodity traders in the UK. The European Commission argues that although the UK may
See MoreEU: Report by European Commission on investor residence schemes
On 23 January 2019 the European Commission issued a report on citizenship by investment and citizenship by residence schemes operated by a number of EU Member States. The report looks at current practices and identifies some of the risks from such
See MoreSpain publishes national budget for 2019
The state budget bill (the Budget Bill) for fiscal year 2019 was published on 16 January 2019 in the Spanish Parliament Official Gazette. The Budget Bill, which was adopted by the Spanish Council of Ministers on 11 January 2019, will now follow the
See MorePortugal modifies the corporate tax return Form-22
On 14 January 2019, the Secretary of State for Fiscal Affairs of Portugal has approves the amendments to the Model 22 periodic income statement, its annexes and instructions for
See MoreItaly: Tax authority releases new WHT return form
On 15 January 2019, Italy’s tax authority issued a Protocol 10656/2019 approving the new electronic withholding tax (WHT) return Form-770/2019 along with instructions for fiscal year 2018. The form must be filed by 31 October
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