Ukraine: MLI enters into force
On 1 December 2019, the Multilateral Convention to Implement Tax Treaty Related Measures to Prevent Base Erosion and Profit Shifting (MLI) entered into force with respect to the Ukraine. On 8 August 2019, Ukraine deposited its instrument of
See MoreUkraine: Parliament adopts law on state budget for 2020
On 14 November 2019, the Ukrainian Parliament has adopted Draft Law on the State Budget of Ukraine for 2020. There is no increase in the general rate of corporate or individual tax. Expenditures are estimated at UAH 1.18 trillion, including general
See MoreUkraine: SFS issues guidance letter on taxation of freight forwarding services
On 20 November 2019, the State Financial Service (SFS) of Ukraine has issued guidance letter no. 1237/6/99-00-07-02-02-15/IPK regarding taxation of freight forwarding services. The letter clarified that the amount of freight paid by a resident
See MoreSerbia: Parliament adopts draft bill to implement CbC reporting obligations
On 18 October 2019, the Serbian parliament accepted for consideration a bill to implement country-by-country (CbC) reporting obligations for multinational entities (MNEs). Under this ultimate parent entities of an MNE group resident in Serbia are
See MoreRussia: MOF clarification on CFC profits
On 5 November 2019, the Russian Ministry of Finance (MOF) issued the letter No. 03-03-06 / 1/85022 concerning the profits of controlled foreign companies (CFC) in cases where a controlling person has an indirect participation in a CFC through legal
See MoreBosnia and Herzegovina signs MLI to implement tax treaty related BEPS measures
On 30 October 2019, Bosnia and Herzegovina signed the Multilateral Convention to Implement Tax Treaty Related Measures to Prevent BEPS (MLI). The countries involved in the Inclusive Framework are working towards implementation of the BEPS
See MoreUkraine: National Bank reduces the interest rate from October 2019
On 24 October 2019, the National Bank of Ukraine decided to lower its key policy rate from 16.5% to 15.5% per annum with effect from 25 October 2019. The interest rate has a tax effect on the late tax payment interest and
See MoreRussia reduces the Interest rate from October 2019
On 25 October 2019, the Russian Central Bank announced the decision to reduce the key rate from 7% to 6.5% with effect from 28 October 2019. For tax purposes, the key rate is important in relation to the safe harbor rates for interest income and
See MoreSwitzerland: Federal Council adopts dispatch on amendments to DTA with Iran
On 23 October 2019, the Swiss Federal Council adopted the dispatch on the protocol of amendment to the agreement with Iran for the avoidance of double taxation with respect to taxes on income and capital (DTA). The protocol implements the minimum
See MoreRussia proposes Tax Policy for 2020 to 2022
On 30 September 2019, the Russian Government submitted the Draft Law to the State Duma. The draft law includes the following measures: The bill aims to change the approach to taxing companies in the digital sector. The draft law recommend that
See MoreUkraine: STS clarifies on determination of profits attributable to PE
The State Tax Service (STS) of Ukraine issued Letter No. 353/ІPK/15-32-05-04-02-15 of 25 September 2019 regarding determination of profits attributable to permanent establishment (PE). Permanent establishment (PE) will be recognized as an
See MoreRussia: MLI enters into force
On 1 October 2019, the Multilateral Convention to Implement Tax Treaty Related Measures to Prevent Base Erosion and Profit Shifting (MLI) entered into force with respect to the Russian Federation. On 18 June 2019 the Russian Federation deposited
See MoreSwitzerland: Federal Council adopts dispatch on protocol of amendment to DTA with Ukraine
On 9 October 2019, the Swiss Federal Council has adopted the dispatch on the approval of a protocol of amendment to the agreement between Switzerland and Ukraine for the avoidance of double taxation with respect to taxes on income and capital
See MoreRussia enacts legislative changes on Transfer Pricing and MAP
On 29 September 2019, the Russian Government signed a Law no. 325-FZ (Amendments to the Tax Code of the Russian Federation) and published in the Official Gazette. The main amendments relating to transfer pricing are as
See MoreRussia publishes amendments related to corporation tax
On 29 September 2019, the Russian Government signed a Law no. 325-FZ (Amendments to the Tax Code of the Russian Federation) and published in the Official Gazette. The main amendments relating to corporate income tax are as follows: Limitation
See MoreSwitzerland: Federal Council proposes reform of withholding tax regime
On 27 September 2019, the Federal Council of Switzerland issued guidelines on a proposed reform of the Swiss withholding tax (WHT) and stamp tax regimes for indirect investments. The primary objective of the proposal for an exemption from
See MoreUkraine: STS clarifies on controlled transactions report
On 18 September 2019, the State Tax Service (STS) of Ukraine explained about the procedure to file report on controlled transactions for transfer pricing purposes. According to the procedure, representative office that does not meet the conditions
See MoreUkraine increases penalties for tax evasion
On 23 September 2019, the Ukrainian President Volodymyr Zelenskyi has signed Law No. 101-IX on amendments to the Criminal Code of Ukraine and the Criminal Procedure Code of Ukraine, as adopted by the Parliament on 18 September 2019. The Law
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