Hungary: Parliament passes budget for 2020
On 12 July 2019, the Hungarian Lawmakers approved the 2020 budget. The budget targets revenue of 21,426.0 billion forints and expenditures of 21,793.0 billion forints, producing a deficit of 367.0 billion forints. Highlighted features of the
See MorePortugal approves amendments to the TP rules
On 19 July 2019, the Portuguese parliament approved Law No. 180/2019, which includes amendments to the country's transfer pricing (TP) rules. The new law changes the following rules: Abolishing the hierarchy in the selection of the transfer
See MoreIreland introduces EU Directive on Dispute Resolution
Ireland has issued Statutory Instrument (S.I.) No. 306/2019 of 5 July 2019, that includes regulations for the purpose of giving effect to Council Directive (EU) 2017/1852 of 10 October 2017 on dispute resolution. The Directive
See MoreMalta introduces EU Directive on Dispute Resolution
On 12 July 2019, Malta has published regulations in the Official Gazette implementing Directive of European Union Council Directive (EU) 2017/1852 of 10 October 2017 on tax dispute resolution mechanisms into domestic law. The regulations came
See MoreLatvia: President signs a Law to ratify BEPS MLI
On 22 July 2019, Latvian President Egils Levits has signed a law for ratification of the Multilateral Convention to Implement Tax Treaty Related Measures to Prevent BEPS (MLI). Latvia must now deposit its ratification instrument to
See MoreHungary: Parliament approves exit tax and hybrid mismatch rule in line with ATAD
On 12 July 2019, the Hungarian legislator passed an anti-tax avoidance rule for the implementation exit tax and hybrid mismatch rules in line with the EU Anti-Tax Avoidance Directive (ATAD). The exit tax rules would apply from 1 January 2020
See MoreLuxembourg: Tax administration updates its CbC reporting guidance page
On 16 July 1019, the Luxembourg tax administration released its CbC reporting guidance page with new updates, including a new user manual for the MyGuichet e-filing system for submitting CbC reports and a new XSD schema (XML). Under the new manual
See MoreIreland introduces new Guidance on CFC rules
On 22 July 2019, Ireland has published a new Tax and Duty Manual, Part 35b-01-01 in respect of the Controlled Foreign Company (CFC) rules, that were introduced by Finance Act 2018 and take effect from 1 January 2019. The manual provides an
See MoreDenmark publishes a notice regarding transfer pricing documentation
On 12 July 2019, the Danish Tax Authority has published a notice (SKM2019.374.SKTST) which establishes a new practice for the importance of whether a transfer pricing documentation in its entirety is available at the time of tax return. The
See MoreLatvia publishes regulations for low value-adding intra-group services
On 9 July 2019, Latvia published Cabinet Regulations No. 324 of 9 July 2019 in the Official Gazette addressing simplified transfer pricing provisions for intra-group low value-added services. The Regulation provides that the general
See MoreDenmark implements EU dispute resolution directive
The Act implementing Council Directive (EU) 2017/1852 of 10 October 2017 in Denmark entered into force on 30 June 2019. The Directive contains provisions on the effective resolution of disputes concerning the interpretation and application of
See MoreGreece: Tax authority clarifies the limitation period for the late filing of tax return
On 1 July 2019, the tax authority published the Circular E.2123 explaining the application of the limitation period in the event of late filing of a tax return. The new Circular amends Circular 1165/2018 in relation to the limitation period of 15
See MoreFrance issues new guidelines for GAAR
On 3 July 2019, the tax authorities published a guidelines regarding the new general anti-abuse rule (GAAR). The new GAAR, which applies from 1 January 2019, targets provisions that focus on tax-driven abuses of law. According to the guidance,
See MoreIceland: MOF Seeks Comments on draft CbC reporting regulations
On 12 July 2019, the Ministry of Finance and Economic Affairs has opened a public consultation on draft CbC reporting regulations. The draft regulation includes the measures outlining the income, taxes, and economic activities of multinational
See MoreSweden transposes EU Directive on Dispute Resolution
On 19 June 2019, a law proposal that implements the EU Tax Dispute Resolution Directive (2017/1852) was presented to the parliament to be transposed into Swedish legislation. If passed, the law will enter into force on November 1,
See MoreNetherlands: Cabinet submits new bill against tax avoidance
The Dutch government published a legislative proposal engaging rules to counter hybrid mismatches into the Dutch corporate income tax act pursuant to the EU Anti-Tax Avoidance Directive as agreed upon in May 2017 (ATAD2). ATAD2 would address tax
See MoreCroatia: Parliament passes EU directive on tax dispute resolution
On 16 June 2019, the Croatian parliament passed a draft bill to implement the EU Directive on Tax Dispute Resolution (2017/1852). The Directive contains provisions on the effective resolution of disputes concerning the interpretation and
See MoreFrance publishes interest rate for shareholder loan for FY ends between June and September 2019
Recently, France has published interest rates for entities whose financial year ended between 30 June 2019 and 29 September 2019 , which are used to determine the deductibility of interest payments to shareholders. The portion of interest payments
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