Romania: Guidance published on form for country-by-country reporting
On 14 November 2017, the tax administration published guidance Order no. 3049/2017 concerning the form to be used for filing country-by-country (CbC) reports. According to Order no. 3049/2017, the “country-by-country reporting” form should be
See MoreSweden: Income of pension funds to be included in the CbC reporting
The Swedish Tax Agency on 8 November 2017, has published a clarification (No. 202 439672-17/111) on any pension funds derived by life insurance companies, foreign occupational retirement institutions and pension funds pay are to be regarded as
See MoreUkraine clarifies classification of transactions with a non-resident legal entity
On October 4, 2017, the State Fiscal Service (SFS) published Letter No. 1945/6 / 99-99-15-02-02-15 / IPK of September 13, 2017, which specifies the classification of transactions with a non-resident legal entity for the purpose of transfer
See MoreRomania: Ordinance amending the Tax Code published
In the Official Gazette no. 885 of 10 November 2017, Emergency Ordinance no. 79 concerning the modification and completion of Law no. 227/2015 regarding the Tax Code has been published by the Romanian Government. According to the new rule a taxpayer
See MoreHungary: New transfer pricing Decree on Transfer Pricing Documentation rules
On 18 October 2017, the Hungarian Ministry of National Economy (NGM) issued a decree on new Transfer Pricing Documentation rules. According to the provisions of the Decree, a group is required to prepare a master file and a local file from fiscal
See MoreBelgium: Government approves draft law on corporate tax reform with fully participation exemption
On 27 October 2017, according to a press release, on the proposal of the Minister of Finance, the government has approved the corporate tax reform. The corporate tax reform process would take place in two phases, 2018 and 2020. Belgium will grant
See MoreHungary: Proposal of increasing VAT registration thresholds
Hungary is working out a plot to strengthen its VAT registration threshold from HUF8 million to a hefty HUF12 million. This will be effective from 1 January 2019. The threshold will not be applicable for non-resident businesses, which must be
See MoreGermany: Capital gains 100% tax-exempt for foreign corporate shareholders
On 25 October 2017, the German Federal Tax Court (decision dated 31 May 2017) ruled in favor of foreign shareholders selling shares in a German corporation. Capital gains realized upon sale of shares in a German resident corporation by non-resident
See MoreDutch government contingency plans to restrict domestic tax consolidation
On 25 October 2017 the Dutch government announced emergency measures to prevent the Dutch tax consolidation rules being used in international tax avoidance structures. The measures are a direct response to ongoing litigation before the EU Court of
See MoreEU takes action against Amazon and Apple in tax cases
The European Commission issued a statement on 4 October 2017 to the effect that it had ordered Amazon to repay EUR 250 million plus interest that it claims Amazon should have paid in taxes on European sales made by the group through its Luxembourg
See MoreSweden updates guidance on CbC reporting
The Swedish tax agency has updated their tax returns and reporting guidance on country-by-country (CbC) reporting requirements on 19 October 2017. The update provides some additional clarifications based on questions that have been received by the
See MoreSpain and Romania sign an agreement to avoid double taxation
On 18 October 2017, the Double Taxation Agreement (DTA) between Spain and Romania was signed for the avoidance of double taxation and the prevention of fiscal evasion with respect to taxes on income, in Bucharest. Once in force and effective, the
See MoreLatvia and Pakistan sign an agreement on avoidance of double taxation
Pakistan and Latvia on October 25, 2017, after the second round of negotiations, concluded an agreement on the Avoidance of Double Taxation with regard to income tax and prevention of tax evasion and avoidance (ADTA). Avoiding the double taxation
See MoreBulgaria: NRA approves CbC reporting format and process
The Executive Director of the National Revenue Agency (NRA) approved the country by country reporting format and procedures on October 31, 2017, by Order No. ЗЦУ-1410. According to NRA, the ultimate parent entity, who is a resident for tax
See MoreGreece: VAT compliant receipts to fight fraud
The Government has announced a monthly lottery on the basis of VAT compliant receipts issued to consumers for trying to reduce VAT fraud. From the last of October, every single VAT receipt issued in the country will display a unique number, which
See MorePoland: Draft bill amendment regarding tax deductibility of intra-group charges
Poland’s Public Finance Commission of the Lower Chamber of Parliament has debated and passed noteworthy changes of the current draft bill on 24th October 2017. Under the draft bill issued by the Government in July, tax deductibility of various
See MoreNetherlands and Zambia: Dutch parliament approves DTA
The lower house of the Dutch parliament approved the Double Taxation Agreement (DTA) with Zambia on 24 October 2017 for the avoidance of double taxation and the prevention of fiscal evasion with respect to taxes on income. Once in force and
See MorePoland: Decree on information regarding transfer pricing documentation
A decree on information to be included in statutory transfer pricing documentation concerning taxpayer transactions with related parties entered into force on 3 October 2017. It lays down a detailed content that must be included in the transfer
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