FinlandRestriction on interest deduction: On 7 March 2019, the Finnish tax administration published new guidelines on the rules on interest deduction restrictions, which were amended to comply with EU Anti-Tax Avoidance Directive (ATAD), and contained a general 25% EBITDA interest deduction restriction for both affiliated and non-affiliated companies party debt with a EUR 500,000 safe harbor for related party debt and a EUR 3 million safe harbor for unrelated party debt.
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LuxembourgMain corporate income tax rate: According to draft budget 2019 presented by Finance Minister to the Chamber of Deputies on 5 March 2019, the corporate tax rate would be reduced from 18% to 17%, while at the same time increasing the income bracket affected by the minimum rate of 15% would be increased from EUR 25,000 to EUR 175,000. For the amounts between EUR 175,000 and EUR 200,000, the tax would be calculated using a formula in which EUR 26,250 is increased by 31% of the income over EUR 175,000. This measure would already be applicable as from the 2019 fiscal year.
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Hong KongCbC reporting requirement-General rule: On 21 March 2019, the Hong Kong Inland Revenue Department announced an extension of 45 days for the submission of the CbC notification in respect of the accounting period beginning 1 January 2018. Therefore, the notification deadline for accounting period beginning 1 January 2018 is 15 May 2019 which was due by 31 March 2019 under the standard rules.
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Czech RepublicRestriction on interest deduction: According to a law published on 27 March 2019, the deduction of excess borrowing cost is limited to 30% of EBITDA or CZK 80 million, whichever is higher. Loans concluded before 17 June 2016 would be grandfathered.  Exceeding the borrowing costs that exceed the limits may be carried forward indefinitely each year with the same limit, but may not be passed to a legal successor.

Special rules for hybrid instruments or entities: Hybrid mismatch rules are introduced in the law published on 27 March 2019 in line with ATAD. Under this, the hybrid mismatch will be addressed by either form of a ‘double deduction’, when one amount (for instance a deductible expense) reduces the tax base in more than one jurisdiction, or the form of a ‘deduction without inclusion’ of the related income in the tax base, when the tax base is reduced in one jurisdiction without the same amount (income) being included in the tax base in another jurisdiction.
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SerbiaSimplified interest rates-Safe Harbour: 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 Gazette of Republic of Serbia No. 13/2019 on 28 February 2019 and entered into force on 8 March 2019.
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Costa RicaCbC reporting requirement-General rule: On 18 March 2019, the Government of Costa Rica published Resolution No DGT-R-008-2019 in the Official Gazette. The resolution amends Resolution DGT-R-001-2018 which aims to clarify that the compliance of CbC reporting only apply to multinational groups. Prior to the amendments the original CbC reporting resolution generally referred to groups or multinational groups in terms of the requirements.
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USAvailability of APA: On February 26, Advance Pricing and Mutual Agreement (APMA) program of IRS, released an excel based functional cost diagnostic model (FCD Model) that is developed in connection with several prior and pending Bilateral Advance Pricing Agreements (APAs) and Competent Authority/Mutual Agreement Procedure (MAP) cases.
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TaiwanMaster file and CbC reporting requirement: On 26 February 2019, National Taxation Bureau of the Northern Area (NTBNA), Ministry of Finance of Taiwan has published a guideline providing on the submission of the Master file and Country-by-Country report by MNEs. The guideline contains general requirements, thresholds, due date and ways of submission of Master file and CbC reporting.
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NigeriaMAP: On 21 February 2019, Nigeria’s Federal Inland Revenue Services (FIRS) has issued guidelines on Mutual Agreement Procedure (MAP). The guidelines prescribe information regarding eligibility for MAP, access to MAP, overview of the MAP request process, and the implementation of a MAP decision.
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IndiaComparable Data: On 7 February 2019, the Kolkata Bench of the Income Tax Appellate Tribunal (the Tribunal) has pronounced its ruling in the case of Philips Medical Systems (P.) Ltd. vs ITO relating to certain transfer pricing issues. The court ruled in the favour of the taxpayer by holding that an entity engaged in both manufacturing as well as trading activity, in the absence of segmental accounts, cannot be a comparable company for benchmarking the taxpayer engaged principally in a trading activity.
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Information exchange: On 27 March 2019, India and the US signed an Inter-Governmental Agreement for exchange of Country-by-Country (CbC) reports of multinational companies regarding income allocation and taxes paid to help check cross-border tax evasion.
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PeruCbC reporting requirement-Timing: On 14 March 2019, the Peruvian tax authorities (SUNAT) issued an administrative regulation (Ruling No.054-2019) that extends the deadlines for the local filing of the CbC reports for Fiscal years 2017 and 2018.
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AustraliaRequirements-Rule:  On 13 March 2019, the Australian Taxation Office (ATO) released its final Practical Compliance Guideline (PCG) 2019/1 for all multinational enterprises (MNEs) with distribution operations in Australia. The Guideline is applied to entities that are engaged in the distribution of goods purchased from related foreign entities for resale and the distribution of digital products or services where the intellectual property in those products or services is owned by related foreign entities.
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