Sweden:Tax Authority declares on the relevance of the TP documentation when filing an incorrect tax return
On 3 December 2018, the tax authority issued Declaration No. 202 251680-18 / 111, on the relevance of Transfer Pricing documentation in the event of a tax surcharge for providing incorrect information. If the company has made an inaccurate task
See MoreBulgaria includes new CFC rule and updates interest limitation rule
On 27 November 2018, Bulgaria published a Bill on amendment and supplement to the Corporate Income Tax Act in the Official Gazette. The Bill includes a new interest limitation and controlled foreign company (CFC) rules in accordance with the EU
See MoreBelgium issues draft TP guidelines for public comments
The tax authority of Belgium has published a draft Circular on the 2017 update to the Organisation for Economic Co-operation and Development (OECD) Transfer Pricing (TP) Guidelines. On 9 November 2018, the draft Circular was published by the Belgian
See MorePoland: President signed an act including amendment of TP measures effective in 2019
On 14 November 2018, President of Poland signed an act including amendment of transfer pricing measures effective in 2019. The new laws repeal the Article 9a of the CIT Act regarding transfer pricing, which is being replaced by Chapter 1a,
See MoreDenmark: Court imposes fines for not providing timely submission of TP documents
On 19 November 2018, the Danish tax authority published an overview of a decision by the Copenhagen Court on whether a company acted in a grossly negligent act for failing to submit the timely submission of transfer pricing (TP) documents and should
See MoreDenmark: The Ministry of Finance releases the new tax limits for 2019
On 14 November 2018, the Danish Ministry of Taxation has published a tax amount limits table for 2019. The table includes various amount limits for tax purposes in relation to individual income tax, although certain other amounts are included for
See MoreBulgaria: MoF proposes new mandatory documentation rule for transfer pricing
On 5 November 2018, the Ministry of Finance (MoF) published a draft consultation, proposing new mandatory documents for transfer pricing documentation, and a penalty for failure to comply with up to 1% of the value of undocumented transactions. The
See MoreBulgaria: Parliament approves budget 2019 at first reading
On 7 November 2018, the National Assembly passed the 2019 Budget Act at first reading with 115 MPs in favor and 85 opposed. The budget proposal containing amendments to the corporate tax laws. The proposed corporate income tax amendments are
See MoreFinland: Ministry of Finance submits a bill on changes to CFC rules to Parliament
On 1 November 2018, the Ministry of Finance submitted a bill to Parliament proposing changes to the CFC rules. Under the proposed rules, the control threshold setting the CFC status would be reduced from 50% to 25%, and the direct or indirect
See MoreLatvia: Parliament adopts regulation with new requirements for transfer pricing documentation
On 25 October 2018 the Parliament approved amendments to the law ‘On taxes and duties’ which introduce in Latvia the OECD format of the transfer pricing documentation. The law was published on 14 November 2018 as the official Gazette no
See MoreGerman passed the Annual Tax Act 2018
On 8 November 2018, the German Federal Parliament (The Bundestag) has passed the Annual Tax Act 2018 under the name “Law on the avoidance of sales tax defaults when trading goods on the Internet and amending further tax regulations”. The German
See MorePoland: Parliament passes tax reform bill for 2019 including MDR
On 26 October 2018, the upper house of the Polish Parliament (the Senate) adopted the draft bill introducing far-reaching changes to the Polish tax law, including European Union (EU) Mandatory Disclosure Rules (MDR). The main difference of the
See MoreEU: European Commission formally notifies Romania on VAT split payment rule
On 8 November 2018 the European Commission sent a formal notice to Romania expressing the view that the VAT split payment mechanism applicable in Romania from 1 January 2018 is not compatible with the EU VAT Directive 2006/112 and is not compatible
See MoreAustria publishes the Annual Tax Amendment Act 2018 in the official gazette
On 14 August 2018, the Annual Tax Amendment Act 2018 has been published in the Austrian Federal Law Gazette no. 62/2018. The Annual Tax Amendment Act 2018 implements the new horizontal monitoring regime and introduces the CFC
See MoreEU: Investment protection agreement with Vietnam
On 17 October 2018 the European Commission adopted an investment protection agreement with Vietnam, at the same time as a free trade agreement. This paves the way for the final signature and conclusion of the investment protection agreement. Under
See MoreEU: Free trade agreement with Vietnam
On 17 October 2018 the European Commission adopted the free trade agreement (FTA) between the EU and Vietnam. The FTA has been presented for signature to the European Council. A factsheet on the FTA with Vietnam has also been issued and sets out the
See MoreMLI enters into force in respect of Sweden
On 1 October 2018, the Multilateral Convention (2016) (MLI) entered into force in respect of Sweden. Sweden signed the convention on 7 June 2017 and deposited its final MLI position on 22 June 2018, including the 64 tax treaties that it wishes
See MoreBulgaria: Council of Ministers approves draft Bill for amending income tax
The Council of Ministers approved a draft bill on October 10, 2018 and it have issued by the Finance Minister, Vladislav Goranov, on the Bulgarian Council of Ministers approved the draft bill issued by the Minister of Finance on 30 August 2018. The
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