FinlandRequirements-Rule: On 30 December 2019, Finnish President approved the Law 1559/2019 for the implementation of Council Directive (EU) 2018/822 of 25 May 2018 (DAC6) on reporting requirements for cross-border tax planning arrangements.
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Special rules for hybrid instruments or entities: On 30 December 2019, the President of Finland signed the Law 1567/2019 that provides for the implementation of the hybrid mismatch rules of the Anti-Tax Avoidance Directive, as amended by Council Directive (EU) 2017/952 (ATAD2).
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RomaniaRequirements-Rule: On 9 January 2020, Ministry of Finance of Romania published a draft bill for the implementation of EU Directive on reportable cross-border tax planning arrangements.
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India Master file-Reporting structure: On 6 January 2020, India’s Central Board of Direct Taxes issued a notification amending the rules for furnishing the Master file (Form 3CEAA)  and the CbC notification (Form No. 3CEAC) for foreign-parented groups which are contained in Rules 10 DB and 10 DA of the Income Tax Rules, respectively.
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LuxembourgCoordination of Domestic and Cross-Border Dispute Resolution Procedures: On 23 December 2019, Luxembourg publishes Law of 20 December 2019 transposing EU Tax Dispute Resolution Directive (2017/1852) into domestic law. The directive includes measures to ensure effective resolution of disputes concerning the interpretation and application of bilateral tax treaties and the Union Arbitration Convention, and in particular, disputes leading to double taxation.
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IcelandDispute resolution-Elements of minimum standards: On 1 January 2020, the Multilateral Convention to Implement Tax Treaty Related Measures to Prevent Base Erosion and Profit Shifting (MLI) entered into force for Iceland.
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DenmarkRequirement-Rule: On 27 December 2019 and on 31 December 2019 Denmark published Law and Executive Order, simultaneously, for the implementation of Council Directive (EU) 2018/822 of 25 May 2018 (DAC6) on reportable cross-border tax planning arrangements (DAC6).
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Dispute resolution-Elements of minimum standards: On 1 January 2020, the Multilateral Convention to Implement Tax Treaty Related Measures to Prevent Base Erosion and Profit Shifting (MLI) entered into force for Denmark.
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BulgariaRequirement-Rule: On 31 December 2019, Bulgaria published a Law on Amendment and Supplementation of the Tax and Social Insurance Procedure Code in the Official Gazette. This Law includes measures to transpose an EU directive on the mandatory automatic exchange of information in relation to reportable cross-border arrangements (DAC6).
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MaltaSpecial rules for hybrid instruments or entities: On 24 December 2019, Malta has published Legal Notice 348 of 2019 implementing EU Anti-Tax Avoidance Directive (2017/952) (ATAD 2) into Malta domestic law which applies to mismatches between EU member states, with non-EU countries, and brings additional types of hybrid mismatches within the scope of the measures.
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Requirement-Rule: On 17 December 2019, Malta published Cooperation with Other Jurisdictions on Tax Matters (Amendment) Regulations 2019 through Legal Notice 342 of 2019 which include the implementation of Council Directive (EU) 2018/822 of 25 May 2018 amending Directive 2011/16/EU as regards mandatory automatic exchange of information in the field of taxation in relation to reportable cross-border arrangements (‘DAC6’).
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ChileDispute resolution-Elements of minimum standards: On 9 January 2020, the Chamber of Deputies approved a Bill for the ratification of the multilateral convention to implement tax treaty related measures to prevent BEPS (MLI).
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EstoniaRequirement-Rule: On 21 December 2019, Estonia has published Tax Information Exchange Act (Amendment) in the Official Gazette for the implementation of Council Directive (EU) 2018/822 of 25 May 2018 (DAC6) on reportable cross-border tax planning arrangements (DAC6).
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PanamaCbC reporting requirement-General rule: The FATCA & AEOI Portal of Panama’s Directorate General of Revenue (DGI) is now accepting registration for Country-by-Country (CbC) report presentation and notification purposes, as well as for FATCA and CRS purposes.
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Dominican RepublicDocumentation-Thresholds: On 15 January 2020, Directorate General of Internal Revenue (DGII) published the Transfer pricing (TP) reporting threshold for 2020. The related party transaction threshold for transfer pricing reporting purposes in 2020 is DOP11,552,402.
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CanadaCbC reporting requirement-General rule: On 9 January 2020, Government announced that as from 1st June 2020, Canadian ultimate parent entities that are corporations must file the RC4649 electronically using EFILE or Web Access Code (WAC).
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IrelandRequirement-Rule: On 22 December 2019, the Irish president signed the Finance Act 2019 which includes new transfer pricing rules incorporating the OECD 2017 Transfer Pricing Guidelines into Irish legislation and gives the introduction of new documentation requirements.

Special rules for hybrid instruments or entities: The Finance Act introduces anti-hybrid rules as required by the European Anti-Tax Avoidance Directives (ATAD). ATAD anti-hybrid rules apply to arrangements between associated enterprises and they apply to all corporate taxpayers, there is no de-minimis threshold.
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ColombiaDocumentation requirement-Master/Local file & CbC reporting:  On 23 December 2019, Colombian tax authority (DIAN) published Decree No. 2345 providing the deadline for transfer pricing (TP) documentation, including local/master file and CbC reports. The deadline for informative transfer pricing returns and Local files is 7 July to 21 July 2020. The deadline for Master file and CbC reports is 10 December to 23 December 2020.
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BelgiumRestriction on interest deduction: On 27 December 2019, a royal decree of 20 December 2019 published in Belgian official journal introduces several changes to the interest deduction limitation rule in the Income Tax Code, often referred to as the 30% earnings before interest, tax, depreciation and amortization (EBITDA) rule.
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Requirement-Rule: On 12 December 2019, the Belgian Parliament adopted legislation implementing the EU Directive on the mandatory disclosure and exchange of cross-border tax arrangements (DAC6) and it was published in the Official Gazette on 30 December 2019.
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UKRequirement-Rule: On 13 January 2020, the final International Tax Enforcement (Disclosable Arrangement) Regulations 2020 that implement the EU mandatory disclosure rules (EU DAC 6 directive) into the United Kingdom (UK) law were published.
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Sri LankaCbC reporting requirement-Timing: On 17 December 2019, the Inland Revenue department (IRD) of Sri Lanka has issued a notice on the filing of Country-by-Country (CbC) reports by MNE groups. The initial notification deadline for the year starting 1 April 2019 was 31 December 2019, and the notification deadline for the year starting 1 January 2020 is 31 December 2020.
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Korea, Rep OfPenalty for documentation failure: From 1 January 2020, an additional penalty of up to KRW200 million (US$170,000) (currently up to KRW100 million) may be imposed every 30 days after the first penalty assessment until the requested TP documents are submitted.
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NetherlandsRequirement-Rule: On 18 December 2019, the Dutch Senate approved the draft legislation implementing the European Union (EU) Directive on the mandatory disclosure and exchange of cross-border tax arrangements (DAC6).
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GermanyRequirement-Rule: On 30 December 2019, the German Official Gazette published a law implementing EU directive on reporting requirements for cross-border tax planning arrangements. The directive requires the taxpayers and intermediaries including EU-based tax consultants, banks and lawyers to report certain cross-border arrangements to the relevant EU member state tax authority.
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