Finland: 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
See MorePortugal implements EU Directive on Dispute Resolution
On 12 August 2019, the Portuguese Parliament has approved the bill to transpose Council Directive (EU) 2017/1852 of 10 October 2017, which includes measures to ensure effective resolution of disputes concerning the interpretation and
See MoreMalta announces deduction rules for patent box regime
On 13 August 2019, the Government of Malta has published Legal Notice 208 of 2019 introducing ‘Patent Box Regime (Deduction) Rules, 2019’ on qualifying intellectual property (IP). The patent box regime grants additional tax deductions on income
See MoreBulgaria modifies the CFC Rules
The recently published Bulgarian Law amending and supplementing the Tax and Social Security Act includes some modifications and explanations of the rules for Controlled Foreign Companies (CFC), which were introduced with effect from 1 January 2019,
See MoreLuxembourg: Government submits EU Anti-Tax Avoidance Directive to Parliament
On 9 August 2019, Luxembourg Government submits draft law to the Parliament for the execution of the expanded hybrid mismatch rules of the European Union (EU) Anti-tax Avoidance Directive as amended (ATAD2). The draft law aims at broadening the
See MoreBulgaria publishes new mandatory TP documentation requirements
On 13 August 2019, amendments to the Tax and Social Security Procedure Code (TSSPC) were published in the State Gazette. The law introduced the mandatory new transfer pricing (TP) documentation requirements in Bulgaria. Documentation
See MoreHungary publishes legislation implementing EU directive on hybrid mismatch rules
On 23 July 2019, Hungary published a legislation through an official gazette that provides for the implementation of exit tax and hybrid mismatch rules of the EU Anti-Tax Avoidance Directive (ATAD). On 12 July 2019, the Hungarian legislator passed
See MoreLithuania implements EU Directive on mandatory disclosure rules
On 30 July 2019, the President signed the primary legislation implementing the European Union (EU) Directive on the mandatory disclosure and exchange of reportable cross-border tax arrangements (referred to as DAC6 or the Directive) into
See MoreBelgium: CbC report corrections guidelines
On 30 July 2019, the Federal Public Service Finance of Belgium issued a notice on its transfer pricing - BEPS 13 guidance page that the MyMinfin Portal is now available for the submission of Country-by-Country (CbC) report
See MoreBulgaria approves CbC Exchange Agreements with U.S.
On 10 July 2019, Bulgaria's Council of Ministers approved two agreements with the United States allowing for the automatic exchange of country-by-country reports. The CbC report is one element of the three-tiered standardized approach to transfer
See MoreBulgaria approves new mandatory TP documentation requirements
On 31 July 2019, the National Assembly approved at second (final) reading amendments to the Tax and Social Security Procedure Code (TSSPC), which introduced the new transfer pricing (TP) documentation requirements. New rules for TP
See MoreFrance: President signs new Law of digital services tax
The new Law No. 2019-759 has been published on July 25, 2019, in the Official Gazette, which introduces Digital Services Tax (DST). It was signed by the French President, Emmanuel Macron, on July 24, 2019. This new Law also modifies the downward
See MoreLuxembourg: DTA with Kosovo enters into force
On 23 July 2019, the Double Taxation Agreement (DTA) between Kosovo and Luxembourg was entered into force and applies from 1 January 2020. The agreement was signed on 8 December 2017. The agreement contains Dividends rate 0% for at least 10%
See MoreDTA between Luxembourg and Uzbekistan enters into force
On 26 July 2019, the amending protocol to the Double Taxation Agreement (DTA) between Luxembourg and Uzbekistan was entered into force and applies from 1 January 2020. The agreement was signed by Luxembourg Minister of Finance Pierre Gramegna and
See MoreLuxembourg: MLI enters into force
On 1 August 2019, the multilateral convention to implement tax treaty related measures to prevent Base Erosion and Profit Shifting (Multilateral Instrument or MLI) entered into force in respect of Luxembourg. MLI provisions that affect withholding
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