Belgium issues a draft bill to introduce some tax measures
On 11 June 2018, a draft bill was submitted to the parliament to complete and amend the corporate income tax reform of 2017. The bill contains a new anti-abuse provision for notional interest deduction (NID) and clarifies that the reduction of
See MoreBelgium issues a FAQs on MAP and APA
On 23 May 2018, the Public Federal Service (SPF) of Belgium published a document of FAQ on Mutual Agreement Procedure (MAP) and the Advance Pricing Agreement (APA) procedure. The assessee may also request that the tax due in Belgium is not invoiced
See MoreDanish Government adopts the PE rules amendments for pass-through entities
On 9 June 2018 Denmark adopted Law No. 725 of 8 June 2018 provides for amendments to the permanent establishment (PE) rules with respect to investments made in Denmark through transparent entities. The amendment excludes foreign investors making
See MoreDanish Government adopts Law on R&D deductions
On 9 June 2018 Denmark adopted Law on R&D Deductions in the Official Gazette. Law No. 722 of 8 June 2018 provides for an increase in the allowed deduction for R&D from the prior 100% to: 101.5% for the 2018 and 2019 tax years; 103% for
See MoreSweden: Parliament approves draft bill regarding corporate income tax changes
On 14 June 2018, the Swedish Parliament approved the bill introducing new tax rules for the business sector. The bill includes following measures: A reduction in the corporate tax rate from 22% to 21.4% in 2019 and 2020, and to 20.6% from 2021;
See MoreIreland: New guidelines on TP compliance
On May 28, Irish Tax and Customs updated Tax and Duty Manual Part 35A-01-01 to set out the government’s approach to monitoring compliance with transfer pricing legislation contained in Part 35A of the Taxes Consolidation Act 1997. The new
See MoreGermany: The CJEU decision permits deviations from the arm’s length principle
On 31 May 2018, the Court of Justice of the European Union (CJEU) issued its decision in the case of: C-382/16 Hornbach-Baumarkt that a parent company’s position as a shareholder of a non-resident company may be taken into account in
See MoreSlovenia 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
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