Peru: Income tax regulations updated to implement significant tax changes in Peru
Belgium: ATAD interest deduction limitation rules apply as from 1 January 2019
Botswana: Transfer pricing, interest deductibility regimes enacted, IFSC regime amended
Denmark: Guidance issued on extension of interest exemption under thin cap rules
European Union: European Commission requests Germany to revise exit tax rules
France: Digital services tax proposal to be presented to parliament
Portugal: 2019 budget law contains corporate, individual and indirect tax changes
South Africa: VAT e-services regulations amended
Thailand: International Business Center regime enacted

World Tax Advisor 9 November 2018

Minister of Finance issues decree on exit tax consequences where Germany’s taxing rights are restricted
Australia: Guidance issued on transfer pricing and financing arrangements
Denmark: Proposals would implement ATAD interest expense deduction limitation rules
Hong Kong: Enhanced deduction regime for R&D expenditure in effect
Italy: Draft 2019 budget law includes changes to tax incentives
Netherlands: Transition rules proposed to apply to shortened term of 30% facility
Ukraine: Draft law on BEPS released

World Tax Advisor 2 November 2018

UK Budget 2018 includes new digital services Tax
Australia: ATO releases guidelines on general anti-avoidance and hybrids
China: Draft IIT implementation regulations released for public consultation
Denmark: New guidance issued on VAT treatment of holding companies
Finland: Income register reporting to be introduced from 2019
Jersey: Draft legislation on company economic substance presented
Netherlands: Consultation launched on measures to implement EU ATAD II into domestic law
New Zealand: R&D tax incentive bill introduced to parliament
Spain: Draft bills issued on digital services and financial transaction taxes, ATAD measures

Thailand approves new IBC regime to replace
existing HQ regimes
Austria: Draft regulation addresses
requirements under new “horizontal
monitoring” procedure
Brazil: 31 December deadline for disclosure of
ultimate beneficiary information
Denmark: Proposals would implement ATAD
hybrid mismatch rules
Netherlands: Supreme Court confirms CJEU decision
in fiscal unity cases
New Zealand: GST on low-value imported goods:
Details of proposed regime released
United Kingdom: MLI-synthesized treaty with Slovenia
published

Aligning R&D arrangements and transfer pricing for MNEs operating in China
Australia: Tax cuts brought forward for companies with turnover under AUD 50 million
Australia: Black economy measures draw a wide net
Denmark: Significant changes to CFC legislation proposed
El Salvador: Tax authorities update tax haven guide
Malta: Rules from EU VAT package on e-commerce implemented
Netherlands: Amendments announced to 2019 tax package
OECD: Residence and citizenship by investment schemes posing CRS avoidance risk identified
Thailand: Lower VAT rate extended for another year

European Commission releases detailed proposal for definitive VAT system
Denmark: Proposed changes would bring thin capitalization rules in line with CJEU decision
France: Courts clarify criteria for determining whether permanent establishment exists
Malaysia: GST expected to be replaced with sales and services tax
Singapore: Removal of intellectual property income from existing tax incentives
Thailand: Guidance issued on tax treatment of cryptocurrency
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