Russia: Parliament approves law on submission of CbC reports
On 7 June 2019, the Russian parliament passed Law No. 125-FZ in the Official Gazette. The Act amends Article 105.16.3 of the Tax Code on the submission of country-by-country (CbC) reports by multinationals (MNE). The amendments extend the list
See MoreRussia proposes Transfer Pricing and MAP-related changes
The Russian Ministry of Finance has proposed some transfer pricing amendments (Draft legislation No. 720839-7) and submitted them to the State Duma for approval (preliminary examination of the draft law submitted to the State Duma). The draft law
See MoreRussia: MOF clarifies the ‘related party’ for transfer pricing purposes
Recently, the Russian Ministry of Finance has adopted a guidance letter (No. 03-12-12 / 1/39688 of 05.31.2019) clarifying the recognition of persons as related for transfer pricing purposes. The Guidance Letter No. 03-12-12/1/39688 says that
See MoreRussia deposits ratification instrument for MLI
On 18 June 2019, the Russian Federation has deposited its instrument of ratification for the Multilateral Convention to Implement Tax Treaty Related Measures to Prevent Base Erosion and Profit Shifting (MLI). According to the date of deposit,
See MoreBulgaria increases VAT registration threshold
Bulgaria is considering raising its VAT registration threshold. The current threshold will rise from BGN 50,000 to BGN 100,000 sales per annum. The new threshold will effective as from 1 January 2019. In addition, it is proposed a new reduced
See MoreDTA between Ukraine and Qatar enters into force
On 9 April 2019, the Double Taxation Agreement (DTA) between Ukraine and Qatar was entered into force and applies from 1 January 2020. The agreement contains Dividends rate 5% for at least 10% capital holding; otherwise 10%, Interest rate
See MoreUkraine: SFS clarifies controlled transactions between a non-resident and its PE in Ukraine
On 19 April 2019, the State Fiscal Service (SFS) of Ukraine published a guidance letter 1723/6/99-99-15-02-02-15/IPK on the treatment of transactions between a non-resident and its permanent establishment (PE) in Ukraine as controlled for transfer
See MoreRussia enacts law regarding taxation of capital gains
Recently, the Russian government has enacted the Federal Law No. 63-FZ of 15 April 15 "On Amendments to the Second Part of the Tax Code of the Russian Federation and Article 9 of the Federal Law". The law slightly changes Article 217 of the Tax
See MoreUkraine: SFS clarifies tax treatment of fines and penalties on non-resident incomes
Recently, the State Financial Service of Ukraine published a guidance letter 1137/6/99-99-15-02-02-15/IPK, which explains the tax treatment of fines and penalties on income paid to non-resident for non-compliance or improper performance of an
See MoreUkraine: SFS issues letter on transfer pricing rules to salaries paid to non-residents
On 29 March 2019, the State Fiscal Service (SFS) of Ukraine issued letter 1358/6/99-99-15-02-15/ІPK on the treatment of salary payments to non-resident persons as controlled for transfer price purposes. The letter states that such payments
See MoreRussia presents a draft bill for the income tax return for small taxpayers
On 21 March 2019, the Russian government announced a bill to amend the income tax return for small taxpayers. The bill requires legal entities with at least 10 employees to file an electronic income tax return and proof of paid insurance from 1
See MoreSwitzerland approves MLI
On 22 March 2019, the Swiss Parliament approved in the final vote the ratification of the multilateral convention to implement tax treaty related measures to prevent Base Erosion and Profit Shifting (MLI). The MLI is subject to an
See MoreRussia: Parliament proposes to reduce the corporate property tax rate
On 6 March 2019, a draft bill was presented to the State Duma (Lower House of Parliament) proposing to lower the maximum amount of the property tax rate to be taxed at the cadastral value. According to the bill, the corporation tax rate for real
See MoreSerbia: Ministry of Finance publishes safe harbor interest rates for 2019
The Serbian ministry of finance has published the Rulebook on arm’s length interest rates that are applicable for 2019, which apply to interest rates on loans and credits between associated parties. The Rulebook was published in the Official
See MoreSerbia: Parliament adopts the law on amendments to the corporate income tax law
On 7 December 2018, the parliament of Serbia adopted the Law on Amendments to the Corporate Income Tax Law (the Law) which was published in the Official Gazette of RS number 95/2018 dated 8 December 2018. The Law came into force on 9 December
See MoreRussia: Finance Ministry publishes Guidance on MAP
On 30 January 2019, the Russian Ministry of Finance published on its official website a guidelines on the mutual agreement procedure (MAP) provided for in double taxation agreements. The guideline contains recommendations for the initiation and
See MoreRussia publishes list of foreign states for automatic exchange of CbC reports
On 25 December 2018, The Federal Tax Service of Russia published a new list of foreign states (territories), with which Russia will automatically exchange Country-by-Country (CbC) reports. Now the list includes 53 foreign countries and 4
See MoreUkraine: Draft law on implementation of BEPS provisions
On 24 October 2018, Ukraine published a draft law on the implementation of some of the recommendation of the OECD/G20 reports on Base Erosion and Profit Shifting (BEPS). The draft law was developed by the Finance Ministry and National Bank supported
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