AustraliaFinancial services: On 28 August 2019, the Australian Taxation Office (ATO) published draft Practical Compliance Guideline PCG 2019/D3, which sets out the proposed compliance approach for the use of the arm’s-length debt test (ALDT) for the purposes of Australia’s thin capitalization regime.
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PolandSpecial rules for hybrid instruments or entities: On 23 August 2019, the Poland Ministry of Finance released a draft bill outlining several provisions to implement EU ATAD 2 anti-hybrid measures.
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UkraineRequirements-Control: On 16 August 2019, the Ministry of Finance issued Order No. 345 providing guidelines on transfer pricing arrangements for transactions between non-residents and their representative offices and permanent establishments in Ukraine.
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U.S.Cost contribution arrangements: On 5 August 2019, the U.S. IRS published a memorandum dated 31 July 2019 on the formal withdraw of Directive LB&I-04-0118-005. Directive LB&I-04-0118-005 was issued on 12 January 2018 and provided instructions for examiners on transfer pricing issue selection related to SBC in CSAs.
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Cost contribution arrangements: On 16 August 2019, the U.S. Court of Appeals for the Ninth Circuit in the case of: Amazon.com, Inc. v. Commissioner, 148 T.C. 108 (2017) issued a decision in favor of Amazon concerning the regulatory definition of intangible assets and the method of their valuation in a cost-sharing arrangement.
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LithuaniaApplicable Methods-Priority of Methods: On 12 August 2019, the tax authorities released the new transfer pricing (TP) rules which provided for the abolition of the hierarchy in the selection of the transfer pricing method.
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ItalyCbC reporting requirement: On 8 August 2019, Italy has published the Ministerial Decree in the Official Gazette amending the Ministerial Decree of 23 February 2017 regarding Country-by-Country reporting (CbCR).
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LuxembourgTreaty Application: On 1 August 2019, the multilateral convention to implement tax treaty related measures to prevent Base Erosion and Profit Shifting (Multilateral Instrument or MLI) entered into force in respect of Luxembourg.
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Special rules for hybrid instruments or entities: On 9 August 2019, Luxembourg Government submits draft law for the execution of the expanded hybrid mismatch rules of the European Union (EU) Anti-tax Avoidance Directive as amended (ATAD2).
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Saudi ArabiaInformation exchange-Multilateral: On 6 August 2019, Saudi Arabian Government signed the Multilateral Competent Authority Agreement (MCAA) for the exchange of Country-by-Country reports (CbCR).
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IndiaCbC reporting requirement: India has amended CbC reporting rules by the Finance (No. 2) Act 2019 which was published on 1 August 2019. Accordingly, if an alternate reporting entity (ARE) in India is designated to file a CbC report, it is the accounting year of the ultimate parent of the MNE group (which is not a resident in India), and not the alternate reporting entity (ARE), that is referenced for the purpose of the CbC reporting obligation.
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IsraelSpecific TP compliance-Form: The tax administration of Israel updated transfer pricing declaration Form-1385, which is a declaration by entities regarding their inter-company transactions with related parties.
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ArgentinaSpecific TP compliance-Form: On 31 July 2019, the Argentina tax authority published a Resolution 4538/2019 extending the due dates for transfer pricing forms F. 741, F. 867, F. 743, and F. 4.501 to the week of 16-20 December 2019 for fiscal periods ending between 31 December 2018 and 30 April 2019.
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BulgariaInformation exchange-Multilateral: On 10 July 2019, Bulgaria’s Council of Ministers approved two agreements with the United States allowing for the automatic exchange of country-by-country reports.
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Documentation requirement: On 31 July 2019, the National Assembly approved at second (final) reading amendments to the Tax and Social Security Procedure Code (TSSPC), which introduced the new transfer pricing (TP) documentation requirements.
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BelgiumCbC reporting requirement: On 30 July 2019, the Federal Public Service Finance of Belgium issued a notice regarding the submission of CbC report file corrections. The notice outlined guidelines on the correction process and new validation elements for corrected XML files.
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RussiaSafe Harbour-Simplified interest rates: On 26 July 2019, the Russian Central Bank announced the decision to reduce the key rate in relation to the safe harbor rates for interest income and expense on controlled debt from 7.50% to 7.25% with effect from 29 July 2019.
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FranceMain corporate income tax rate: The corporate income tax rate has been modified under the Law No. 2019-759 published on July 25, 2019.
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HungarySpecial rules for hybrid instruments or entities: On 23 July 2019, Hungary published a legislation through an official gazette that provides for the implementation of exit tax and hybrid mismatch rules of the EU Anti-Tax Avoidance Directive (ATAD).
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NorwayInformation exchange-Multilateral: On 17 July 2019, Norway deposited its instrument of ratification for the multilateral convention to implement tax treaty related measures to prevent base erosion and profit shifting (MLI). The MLI will enter into force on 1 November 2019 for Norway.
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