Slovenia publishes the clarification on MAP procedure
The Ministry of Finance of the Republic of Slovenia published the clarification on the Mutual Agreement procedure (MAP) on 7 May 2018, which is set out in the MAP scheme of the Slovenian Tax Treaty Network. The clarification provides detail in the
See MoreHong Kong and Finland enter into comprehensive avoidance of double taxation agreement
On 24 May 2018, Hong Kong and Finland signed a comprehensive avoidance of double taxation agreement (CDTA). The CDTA sets out the allocation of taxing rights between the two jurisdictions and will help investors better assess their potential tax
See MoreGermany: Federal Fiscal Court doubts the constitutionality of additional payment interest
On 14 May 2018, the Federal Finance Court (BFH) issued a decision suspending the additional default interest of 0.5% per month for unpaid taxes. The additional interest is considered unconstitutional. The simple penalty of 0.5% applies to every full
See MoreLatvia: Cabinet Ministers approves a draft bill on Master and Local file
Recently, the Latvia Cabinet of Ministers has approved a draft law for the introduction of Master and Local file requirements in line with BEPS Action 13. Under the law, taxpayers resident in Latvia are required to submit Master file within 12
See MoreNetherlands publishes new transfer pricing decree
The Dutch Ministry of Finance published a new transfer pricing decree nr. 2018-6865 on 22 April 2018, which was published in the State Gazette on 11 May 2018. The Decree is in line with the outcomes of the Base Erosion and Profit Shifting (BEPS)
See MorePoland: Parliament enacts draft bill regarding supporting new investments
The lower chamber of the parliament enacted a draft bill regarding Supporting New Investments ( Ustawa o wspieraniu nowych inwestycji ) on 10th May 2018. The draft law will be presented to the higher chamber after some amendments. According to the
See MoreItaly issues final transfer pricing regulations on the application of the arm’s length principle
Italy issued final transfer pricing regulations on May 14 regarding the application of the arm’s length principle. The publication follows the release of a draft for public consultation in February and a consultation in May. The guidance supports
See MoreLithuania: MoF proposes to amend the Corporate Income Tax Law
The Ministry of Finance has published a bill to ease the restrictions on the preferential corporate tax rate (5%) for SMEs. The bill, which was published in the Official Journal on 7 May 2018, and the adoption by Parliament, will enter into force on
See MoreFinland: Tax administration issued guidelines on the allocation of profits to PE
On 30 April 2018, the tax administration published a guideline no.A72/200/2018 on profit distribution for a permanent establishment (PE). The guidelines clarify that, upon request, a foreign company has to specify how it has allocated profits to a
See MoreMalta ratifies MLI
On 27 April 2018, Legal Notice 142 of 2018, which ratifies the BEPS Multilateral Instrument (MLI) in Malta, was published in the Official Gazette No. 19,984. Malta now needs to deposit its instrument of ratification, approval or acceptance of the
See MoreSweden: The Draft legislation regarding corporate tax changes submits to the parliament
On 3 May 2018, the draft law was submitted to the Swedish Parliament for the introduction of new tax rules for the corporate sector. The proposal comprises new rules on re interest deductions, financial leasing and a reduced corporate tax rate. The
See MoreBelgium updates investment allowance rates
According to a Notice 2018/11763 in the Official Gazette the investment allowance rates for the 2019 assessment year. Companies Allowance Rate Applies on 13.50% Investments in patents; environmentally friendly R&D; and energy saving and
See MoreFrance: Senate approves Multilateral Instrument (MLI)
On 19 April 2018, the Senate approved the multilateral convention to implement tax treaty related measures to prevent BEPS (MLI). The agreement will enable France to implement international tax cooperation initiatives, including the automatic
See MoreFinland: Parliament adopts a bill aligned with EU Directive on Exchange of Information
On 6 April 2018, Parliament adopted a bill amending the relevant provisions of the Taxation Act in order to clarify the wording of the provisions of Council Directive (EU) 2016/881 of 25 May 2016 on administrative cooperation in the taxation of
See MoreItaly: Transfer pricing consultation responses published
On 5 April 2018, the Ministry of Economy and Finance published the responses received to the public consultation on transfer pricing legislation launched in February 2018. Comments and proposals are available on the website of the Ministry of
See MoreLuxembourg: Parliament adopts the new IP regime
On 17 April 2018, the Bill on a new IP regime adopted was by the parliament. This will enter into force with retroactive effect as from 1 January 2018. The IP regime introduces a new article 50 ter into the Income Tax Law (ITL) that provides for an
See MoreGreece: Parliament adopts draft bill regarding Multilateral Competent Authority Agreement
The Greek Parliament adopted a draft bill on April 19, 2018, which ratifies the Multilateral Competent Authority Agreement between Greece and United States on the exchange of country by country (CbC) reports. The CbC report is one element of
See MoreDenmark: Eastern High Court applies contemporaneous transfer pricing documentation rule
On 28 March 2018 a summary of a decision of the Eastern High Court in a transfer pricing case involving Microsoft Denmark was published. The case was dealt with by the Supreme Court at first instance after the court had referred it as principle. The
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