UK amends hybrid capital instruments rules
The ‘hybrid capital instruments’ rules are relied upon since 1 January 2019 by many banks and insurers to give corporation tax relief for the coupon payments on regulatory capital securities. These rules have recently been amended by the
See MoreRomania introduces mandatory online submission for CbC Reporting
On 19 August 2019, Romania has published Order No. 2.273, amending the rules on submission of Country-by-Country (CbC) reports and notifications, effective from 26 August 2019. Now both CbC reports and notifications must be submitted through
See MoreGermany proposes corporate tax rate cut for SMEs
On 29 August 2019, the German Economy Minister announced the outline of a plan to reduce the tax and regulatory burden on small and medium-sized enterprises (SMEs) in Germany. The Minister also suggested reducing the tax burden on SMEs by
See MoreRomania implements EU Directive on Dispute Resolution
On 22 August 2019, Romania has published Ordinance No. 19 in the Official Gazette, which implemented the EU Tax Dispute Resolution Directive 2017/1852 in the tax procedure code (Law no. 207/2016). The provisions apply to complaints submitted
See MoreIreland: Finance Department publishes feedback statement regarding TP rules
In February 2019, the Finance Department carried out a public consultation on Ireland’s transfer pricing rules indicating the intended direction in respect of certain recommendations contained in the Coffey Review and seeking stakeholders
See MoreFrance: Tax Authority issues a Ruling on interest deduction
The tax authority issued a ruling regarding the deductibility of interest paid to a related Belgian company benefiting from the notional interest regime. On 4 September 2019, the French General Directorate of Public Finance clarified that tax
See MoreDTA between Croatia and Japan enters into force
On 5 September 2019, the Double Taxation Agreement (DTA) between Croatia and Japan (2018) will enter into force. The treaty generally applies from 5 September 2019 for the provisions of article 25 (Exchange of Information) and article 26
See MoreLuxembourg implements EU Directive on mandatory disclosure rules
On 8 August 2019, the Luxembourg Government submitted draft law 7465 to the parliament to implement the European Union (EU) mandatory disclosure rules and exchange of information on cross-border tax arrangements (DAC6 or the
See MoreSlovenia implements the mandatory disclosure rules
On 28 May 2019, the Slovenian Parliament has approved the EU Directive on the mandatory disclosure and exchange of cross-border tax arrangements (DAC6). The final Slovenian Mandatory Disclosure Rules legislation is significantly aligned to the
See MorePoland: Ministry of Finance publishes a draft bill to implement EU ATAD 2 anti-hybrid measures
On 23 August 2019, the Poland Ministry of Finance released a draft bill outlining several provisions to implement EU ATAD 2 anti-hybrid measures. The main purpose of implementing the anti-hybrid measures is to counteract the situation of double
See MoreDTA between Kosovo and Malta enters into force
On 20 September 2019, the Double Taxation Agreement (DTA) between Kosovo and Malta will enter into force and applies from 1 January
See MoreSingapore REIT eligible for WHT exemption in Italy
On 26 August 2019, the Italian tax authority has published Ruling No. 345 regarding the eligibility of a real estate investment trust (REIT) established in Singapore for the withholding tax (WHT) exemption on income derived through a
See MoreBangladesh’s Cabinet approves the signing of a DTA with Czech Republic
On 26 August 2019, Bangladesh’s Cabinet approved the signing of a double taxation agreement (DTA) between Bangladesh and Czech
See MoreNorway launches a consultation proposal on changes to the group contribution rules
On 13 August 2019, the Ministry of Finance published a proposal to amend the group contribution rules regarding EFTA Court rule of 13th September 2017, which found that Norway's rule violated freedom of establishment rights in cases where there is
See MoreFinland: Ministry of Finance announces the budget proposal for 2020
On 16 August 2019, the Finnish Ministry of Finance announced the proposal for the 2020 budget package. The proposal includes following tax measures: A gradual increase tobacco tax by EUR 200 million over the period 2020 to 2023An increase in
See MoreItaly updates CbC reporting requirements
On 8 August 2019, Italy has published the Ministerial Decree in the Official Gazette amending the Ministerial Decree of 23 February 2017 regarding Country-by-Country reporting (CbCR). The Decree amends Article no. 7 on the use of CbC
See MoreDenmark: Tax Agency allows for the opportunity to re-open certain transfer pricing cases
On 12 July 2019 the Danish Tax Agency issued a new decree (SKM2019.374.SKTtST) regarding transfer pricing documentation in response to the Supreme Court’s decision in the Microsoft case. The decree allows some taxpayers to reopen Denmark transfer
See MoreLithuania further changes TP documentation rules
On 12 August 2019, the tax authorities released the new transfer pricing (TP) rules, which will apply from 2019, in addition to the previously announced new TP rules. The tax authorities also include the following TP measures: Abolishing the
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