| Hungary | Documentation-Timing: On 8 May 2019, the Hungarian National Tax and Customs Administration issued a notice to remind taxpayers that they must prepare their transfer pricing documentation by 31 May 2019 if they are required to keep transfer pricing records and closed their business year on 31 December 2018. See the story in Regfollower |
| Poland | CbC reporting requirement-General rule: On 15 April 2019, Poland published the Act of 4 April 2019 amending the Act on the exchange of tax information with other countries and certain other acts including Country-by-Country (CbC) reporting rules. Under this, if a group prepares its consolidated financial statements in Polish zloty (PLN), the consolidated turnover threshold for CbC reporting is PLN 3,250,000,000. Otherwise, the threshold will be EUR 750 million or the equivalent. The Act entered into force on 29 April 2019. CbC reporting requirement-Timing: The Act of 4 April 2019 published on 15 April 2019 changes the deadline for submission of CbC notification from the last day of the reporting year to within three months following the end of the reporting fiscal year. See the story in Regfollower |
| New Zealand | Requirements-Rule: On 29 April 2019, Inland Revenue published the final versions of the special reports on the new rules for base erosion and profit shifting (BEPS). The new rules are comprised of five separate reports, addressing special transfer pricing interest limits for controlled inbound financing, transfer pricing in general, administrative measures, hybrids, and permanent establishments. See the story in Regfollower |
| Peru | Restriction on interest deduction: On 23 April 2019, the Tax Administration (SUNAT) of Peru issued Administrative rule 033-2019-SUNAT/7T0000 regarding the application of the Peruvian thin capitalization rules which specify a restriction of the deduction of interest on loans where a debt-equity ratio of 3:1 is exceeded. See the story in Regfollower Requirements-Rule: On 16 May 2019, Peruvian tax administration published a guidance “Informe No. 057-2019-SUNAT/7T0000” outlining the tax treatment of transfers of undervalued Peruvian entity shares involving foreign related parties. See the story in Regfollower |
| Bulgaria | Requirements-Rule: On 15 May 2019, the Council of Ministers approved the proposals of the Ministry of Finance to amend the Rules of Procedure on taxes and social security. The amendments concern the introduction of compulsory transfer pricing documentation and the Law Implementing the EU Tax Litigation Directive (2017/1852) of 10 October 2017. See the story in Regfollower |
| Greece | Restriction on interest deduction: On 24 April 2019, Greece published Law 4607/2019 in the Official Journal containing measures to implement certain aspects of the EU’s Tax Avoidance Directive (ATAD). Accordingly, the deduction of net interest expense (borrowing costs) is limited to 30% of EBITDA. The 30% limitation does not apply to exceeding borrowing costs up to the amount of Euro 3M. Taxpayers are entitled to carry forward indefinitely, exceeding borrowing costs above the 30% limitation. See the story in Regfollower |
| Belgium | BEPS related compliance-Local File: The Belgian Federal Public Service (SPF) Finance has published an update version 2.1 of the XML tool and the XSD schema for the Transfer Pricing (TP) Local file (Form 275 LF), which must be used for Local files submitted via the MyMinfin platform from 28 May 2019. Local files created using the prior version of the tool may be submitted up to 27 May 2019. See the story in Regfollower BEPS related compliance-CbC reporting requirement: The annual Country-by-Country (CbC) notification requirement has been amended by the law of 2 May 2019 that was published in the Belgian Official Gazette on 15 May 2019. This new law amended Belgian Transfer Pricing (TP) reporting obligations, reducing the compliance burden for Belgian entities obliged to file a Country-by-Country notification form (275 CBC NOT). A new section (§ 3) is included to the Belgian Income Tax Code’s (ITC) article 321/3, which deals with the CbC notification requirement. See the story in Regfollower Tax returns must be filed: The tax authority of Belgium has declared corporate income tax (CIT) return filing deadlines for the 2019 tax year, with a concession for those with a deadline prior to September 26, 2019. See the story in Regfollower |
| Indonesia | Adjustments-MAP: On 26 April 2019, the Minister of Finance (MoF) issued a new provision regarding the Mutual Agreement Procedure (MAP) through the Minister of Finance Regulation Number 49 / PMK.03 / 2019. PMK-49 became effective as of 26 April 2019 and provides specific procedures and timelines for the MAP application. See the story in Regfollower |
| Austria | Corporate tax rates (current): On 8 May 2019, the Austrian Ministry of Finance published a draft bill regarding tax reform for 2019-2020 including a reduction in the corporate tax rate from 25% to 23% in 2022 and to 21% in 2023. See the story in Regfollower |
| India | Availability of APA: On 3 April 2019, the Central Board of Direct Taxes (CBDT) has announced the signing of 18 advance pricing agreements (APAs) during March 2019, including three bilateral APAs. The total number of APAs entered into by the CBDT as of now stands at 271, which inter alia includes 31 bilateral APAs. See the story in Regfollower |
Transfer Pricing Brief: June 2019
June 03, 2019
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