Hong Kong CbC reporting requirement-General rule: On 1 February 2019, Hong Kong Inland Revenue Department (IRD) announced that effective from 1 April 2019, the department will not accept voluntary filing of a CbC return for an accounting period ended on or before 31 March 2018.
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Croatia Restriction on interest deduction: The Croatian Minister of Finance, referring to National Gazette 118/2018 of 27 December 2018, has declared to reduce the interest rate on loans between related parties from 4.55% to 3.96% per annum. The reduction of so called the arm’s length interest rate became effective from 1 January 2019.
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Brazil For import transactions: On 29 January 2019, the Federal Revenue Department of Brazil (RFB) published the Normative Instruction (NI) 1870/2019 amending NI 1312/12 on some aspects of transfer pricing rules, which mainly related to transactions and commodities.
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Russia Adjustments-MAP: On 30 January 2019, the Russian Ministry of Finance published on its official website guidelines on the mutual agreement procedure (MAP) provided for in double taxation agreements. The guideline contains recommendations for the initiation and implementation of Mutual Agreement (MAP) procedures with the competent authorities of the tax convention partner countries.
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Belgium Restriction on interest deduction: On 31 January 2019, the parliament of Belgium approved legislation implementing the 30% of Earnings before interest, tax, depreciation and amortization (EBITDA) restriction on interest deduction to 1 January 2019. The restriction is according to the EU Anti-Tax Avoidance Directive, with an effective date of 1 January 2020.
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Penalty for documentation failure: According to Circular Letter No. 2019/C/14 published on 8 February 2019, there is no penalty in case of violation independent from the will of the taxpayer. In case of violation without the willful intent to harm or to commit fraud the minimum penalty is EUR 1,250 and not more than EUR 25,000 as from the second violation until the fifth and following. In case of violation with the willful intent to harm or to commit fraud the penalty for the first violation is EUR 12,500 and for the second violation and following EUR 25,000.
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Colombia Specific TP compliance-Form: On 15 January 2019, Directorate of Taxes and National Customs (DIAN) of Colombia published Administrative Regulation 000004 of 2019 to provide the transfer pricing return and other forms for 2019. Submission of Form 120 is generally required if the total capital of the taxpayer at the end of the year amounts to at least 100,000 UVT or the total income is at least 61,000 UVT.
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Saudi Arabia Requirements-Rule: On 15 February 2019, the Board of Directors of General Authority of Zakat and Tax (GAZT) of Saudi published a resolution approving transfer pricing Bylaws as well as an additional FAQs document. The law consists of 26 articles, divided into 12 chapters, which explain the basic principles of transfer pricing through transactions between relevant persons or persons under common control.
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Ireland Requirements-Rule: On 18 February 2019, Department of Finance of Ireland released the public consultation document to update transfer pricing regime, with an effective date of 1 January 2020. The consultation looks for feedback on a number of aspects of existing transfer pricing regime.
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Slovak Republic Documentation-Requirement: The Ministry of Finance of the Slovak Republic issued new guidelines no.MF/019153/2018-724 (MF SR Guidelines 2018) on content of the transfer pricing (TP) documentation which was issued in December 2018 replacing the Guidelines no.MF/014283/2016-724 (MF SR Guidelines 2016). According to the new Guidelines, there are 3 types of documentation such as simplified, basic, and full-scope. Now the tax payers are obliged to keep the complete documentation for cross-border transactions or a group of transactions which may be combined and exceed the amount of EUR 10 million.
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Chile Specific TP compliance-Form: The Internal Revenue Service (IRS) has issued a new version of the annual transfer pricing tax return (Form 1907) to be used in 2019, and includes new sections on Country Reporting (CbC). The IRS also added the instructions of the 1907 form.
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