| Slovenia | Main corporate income tax rate: Slovenia increased the corporate income tax rate from 19% to 20% with minimum tax rate 7% under the amendments of corporate income tax act. Special rules for hybrid instruments or entities: Slovenian government adopted the hybrid mismatch rules of ATAD2 to counter double deduction and deduction without inclusion mismatches under the amendments of corporate income tax act. The changes will apply from 1 January 2020. See the story in Regfollower |
| Turkey | Main corporate income tax rate: On 24 October 2019, the Turkish Government submitted a new draft law to the Parliament which proposes to reduce corporate tax from 22% to 20% in 2020, with a consecutive reduction to 18% in 2021 for nonfinancial institutions. See the story in Regfollower |
| Norway | Restriction on interest deduction: Norway proposes to amends interest deduction limitation rules under the budget proposal of 2020 presented on 7 October 2019. Under existing legislation, interest would not be limited if the de minimis exemption of NOK 25 million applies to the Norwegian part of the group. According to the budget proposals, the “old rules” would apply even if the de minimis exemption applies. See the story in Regfollower |
| Bulgaria | Special rules for hybrid instruments or entities: On 9 October 2019, a draft Law on “Amendment and Supplementation of the Corporate Income Tax Act” was presented to the National Assembly (NA). The bill proposes a provision transposing the anti-hybrid mismatches rules of EU Directive 2017/952 (2017) (ATAD II). The proposed hybrid mismatch rules apply to transactions between associated entities effective from 1 January 2020. See the story in Regfollower |
| Cyprus | Specific TP compliance-Form: On 3 October 2019, the Cyprus tax department has published corporate income tax return form (TD4) for 2018. The only difference between the 2018 and 2017 income tax return template is an addition made in Part 3 – “Computation of Taxable Income”. The return for 2018 must be submitted electronically via the TAXISNET portal. See the story in Regfollower |
| Russia | Adjustments-Treaty Application: On 1 October 2019, the Multilateral Convention to Implement Tax Treaty Related Measures to Prevent Base Erosion and Profit Shifting (MLI) entered into force with respect to the Russian Federation. On 18 June 2019 the Russian Federation deposited its instrument of ratification for the MLI. See the story in Regfollower |
| India | Adjustments-Secondary adjustment: On 30 September 2019, India amended the rule 10CB which provide for computation of interest income relating to secondary adjustments, particularly those arising following the conclusion of an advance pricing agreement (APA) under a mutual agreement procedure (MAP) in an applicable tax treaty. See the story in Regfollower |
| Ireland | Requirement-OECD Guidelines: On 16 October 2019, Irish government published Finance Bill 2019, which contains legislation to makes a number of changes to Ireland’s transfer pricing rules, including directly referencing the latest OECD Transfer Pricing Guidelines into Irish legislation, introducing enhanced transfer pricing documentation requirements, and extending the scope to cover certain non-trading and capital transactions. Special rules for hybrid instruments or entities: The Finance Bill introduces anti-hybrid rules as required by The European Anti-Tax Avoidance Directives. The ATAD directives were agreed to ensure that EU Member States implemented certain OECD BEPS rules in a coordinated way. See the story in Regfollower |
| Brazil | Tax treatment for cost contribution arrangements: On 2 October 2019, the Brazilian tax authorities released a private ruling PLR 276/2019 on tax treatment of cross-border cost sharing arrangements. Under this, remittances to the foreign headquarter company would be subject to taxation applicable to service arrangements. See the story in Regfollower |
| Greece | Main corporate income tax rate: On 7 October 2019, the Finance Minister presented the draft budget for 2020 to the Parliament. The draft budget proposed a gradual reduction of the tax rate from 29% to 25% in a 4 years period, with the resulting fiscal impact starting from 2020 onwards. See the story in Regfollower |
| Zambia | Requirements-Rule: On 27 September 2019, the Minister of Finance (MOF) presented the budget for 2020 to the National Assembly. According to the budget, the law redefines the terms “Actual conditions”, “Arm’s length conditions” and “related or associated persons”. In addition, budget amends the transfer Pricing provisions under Section 97A (13) and (14) of the Income Tax Act. See the story in Regfollower |
| Ukraine | Requirements-Control: On 18 September 2019, the State Tax Service (STS) of Ukraine explained about the procedure to file report on controlled transactions for transfer pricing purposes. Accordingly, representative office that does not meet the status of PE will not considered as a corporate taxpayer and not require to submit report on controlled transactions. See the story in Regfollower |
| Argentina | Requirements-Rule: On 2 October 2019, tax authority of Argentina (AFIP) announced a public consultation and posted on the AFIP website a draft resolution concerning transfer pricing compliance procedures. It would replace the existing transfer pricing rules in General Resolution 1122/2017. See the story in Regfollower |
| Peru | CbC reporting requirement-General Rule: On 29 September 2019, the Peruvian Tax Administration (SUNAT) published the Resolution 188-2019-SUNAT regarding the rules for filing CbC reports. The resolution implements an electronic system that requires taxpayers to submit their CbC reports as of 1 October 2019 regardless of the tax period to which the CbC report corresponds. The resolution came into force on 30 September 2019. See the story in Regfollower |
Transfer Pricing Brief: November 2019
November 06, 2019
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