Russia reduces the interest rate from July 2019
On 26 July 2019, the Russian Central Bank announced the decision to reduce the key rate from 7.50% to 7.25% with effect from 29 July 2019. For tax purposes, the key rate is important in relation to the safe harbor rates for interest income
See MoreUkraine signs amending protocol to DTA with UAE
On 24 July 2019, the Cabinet of Ukraine approved to sign an amending protocol to the Double Taxation Agreement (DTA) with United Arab Emirates (UAE). The provisions of the draft protocol fully comply with the requirements with the Organization for
See MoreUkraine: DTA signs with Oman
On 24 July 2019, the Cabinet of Ukraine authorized to sign a Double Taxation Agreement (DTA) with Oman. The agreement contains Dividends rate 5% for at least 20% capital holding; otherwise 10%, Interest rate 10%, and Royalties rate
See MoreLuxembourg: DTA with Kosovo enters into force
On 23 July 2019, the Double Taxation Agreement (DTA) between Kosovo and Luxembourg was entered into force and applies from 1 January 2020. The agreement was signed on 8 December 2017. The agreement contains Dividends rate 0% for at least 10%
See MoreOECD: Bosnia and Herzegovina joins the inclusive framework on BEPS
On 10 July 2019 the OECD announced that Bosnia and Herzegovina has joined the Inclusive Framework on base erosion and profit shifting (BEPS). This means that a total of 131 countries and jurisdictions are taking part in the Inclusive Framework.
See MoreRussia reduces the interest rate from June 2019
Recently, the Board of Directors of the Bank of Russia decided to lower its key (interest) rate from 7.75% to 7.50% with effect from 17 June 2019. The key rate has an effect on the interest penalties, which increase together with the increased
See MoreUkraine: SFS clarifies treatment of controlled transactions with Bulgaria
On 20 June 2019, the Ukraine State Fiscal Service published a guidance letter No. 2826/6/99-99-15-02-02-15/IPC defining the treatment of transactions with residents of tax Bulgaria, which was removed from the Cabinet tax haven list in April
See MoreMalta: Commissioner for revenue issues updated MAP guidelines
Earlier the month of June 2019, the Maltese Commissioner for Revenue issued guidance under the provisions of article 96(2) of the Income Tax Act, Chapter 123 of the Laws of Malta (the ‘ITA’) on the use of Mutual Agreement Procedure
See MoreRussia: 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
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