Belgium: Ministry of Finance publishes decree on transfer pricing documentation penalties
On 2 August 2018, the Belgian Ministry of Finance published the Royal Decree of 29 June 2018 on administrative penalties for transfer pricing documentation. Taxpayers who do not meet the reporting and registration requirements for transfer pricing
See MoreCroatia: Parliament publishes incentive regime for R&D projects
The Parliament has published the Law on State Aid for Research and Development Projects on July 18, 2018. This Act provides for the implementation of state aid measures for R&D projects. This Law was entered into force on the eighth day after
See MoreSlovak Republic: President signs a Law to ratify BEPS MLI
The Slovak President, Andrej Kiska, has signed a Law on July 30, 2018, for ratification of the Multilateral Convention to Implement Tax Treaty Related Measures to Prevent BEPS (MLI). This means that Slovak Republic has completed the domestic
See MoreSpain publishes budget act of year 2018
On 4 July 2018, the Spanish Government published Law 6/2018 (the Budget Law 2018) in the Official Journal. The law implementing the fiscal measures from the fiscal year 2018 entered into force on 5 July 2018. Budget contains changes to the patent
See MoreFrance: Court rules transfer pricing re-assessment in determining tax on added value
French tax authorities can consider income that is not “booked” in the accounts of the taxpayer-company for purposes of determining a tax on added value (“Cotisation sur la Valeur Ajoutée”—CVAE) as held by the French Supreme Tax Court
See MoreRomania permits quarterly dividend distributions
On 10 July 2018 the Romanian legislature passed Law no 163/2018 in the Official Gazette allowing quarterly dividend distributions.The Law amended the Accounting Law 1991 and the Companies Law 1990 to provide companies with the option to distribute
See MorePoland releases draft law amending transfer pricing rules
On 16th July 2018, Poland has released a bill to amend the country's transfer pricing rules in line with the results of the BEPS project and the OECD transfer pricing guidelines 2017 in order to improve the taxation of large multinational companies.
See MoreFrance: Tax authority publishes transfer pricing guidelines related to BEPS compliance
On 18 July 2018, the French tax authorities published instructions regarding Master / Local file in the context of transfer pricing documentation. As per the guidelines, the new documentation requirements apply for fiscal years beginning on or
See MoreFrance ratifies MLI to implement tax treaty related measures to prevent BEPS
On 12 July 2018, France ratified the bill by way of Law No. 2018-604, as published in Official Journal No. 0160 of 13 July 2018. On 5 July 2018, the National Assembly passed the bill for the ratification of the multilateral convention to implement
See MoreFrance publishes arm’s length interest rate for third quarter of fiscal year 2018
The arm’s length interest rates used in determining the deductibility of interest payments to shareholders for companies whose fiscal year ends between 30 June 2018 and 29 September 2018 has been published by France. The portion of interest
See MoreU.S. and Croatia sign an agreement on the exchange of CbC reports
On 10 July 2018, the competent authorities of the U.S. and Croatia have concluded an arrangement on the exchange of country-by-country (CbC) reports. The competent authority arrangement (CAA) for exchange of country-by-country reports is on the
See MoreAustria: Parliament adopts the annual Tax Act 2018
On 11 July 2018, the Federal Council of Austria adopted the text of the Annual Tax Act 2018 as approved by the National Council (lower house) on 4 July. The legislation includes simplifications of tax laws, the abolishment of various fees and
See MoreNew Zealand-Sweden: Deposit ratification instrument for BEPS MLI
New Zealand and Sweden deposited their ratification certificates on 27th June and 22nd June 2018, respectively for the multilateral agreement on the implementation of tax-relevant measures to prevent erosion and profit shifting (MLI). The MLI will
See MoreIreland updates CbC Report submission guideline
On 19 July 2018, Irish revenue authority published a Tax and Duty Manual Part 38-03-21 to confirm that requests for technical support in relation to Country-by-Country Reporting must be submitted to Revenue using MyEnquiries through the Revenue
See MoreNetherlands submits legislative proposal to implement ATAD postponed
The Secretary of State for Finance has forwarded Letter no. 2018-0000119097 to the Lower House of Parliament on 13th July 2018, announcing that the legislative proposal to implement the EU's Anti-Tax Avoidance (EU) Directive 2016/1164 (2016) (ATAD1)
See MoreAustria: Parliament approves Exchange of CbC Reports and Financial Account Information
On 11 July 2018, the Federal Council (upper house of parliament) of Austria adopted two declarations as approved by the National Council (lower house) on 4 July 2018. The two declarations are relating to the effective date of the multilateral
See MoreLuxembourg: Government submits a bill for ratification of the MLI to parliament
On 3 July 2018 the Luxembourg government submitted the bill for ratification of the Multilateral Instrument (“MLI”) to parliament. On 15 June 2018, the Cabinet was approved this bill for ratification of the Multilateral Instrument
See MoreLithuania ratifies multilateral convention to implement tax treaty related measures to prevent BEPS (MLI)
On 14 June 2018, Lithuania ratified the Multilateral Convention to Implement Tax Treaty Related Measures to Prevent BEPS (MLI) by the Law No. XIII-1271, as published in the Official Gazette on 26 June 2018. This means that Lithuania has completed
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