News December 2019

LOCAL NEWS

Croatia – Lower tax rate for certain companies
According to the changes adopted on 29 November 2019 the companies with annual revenues of less than HRK 7,5 million (currently HRK 3 million) are taxable at the corporate tax rate of 12%. Amendments are effective from from 1 January 2020.

France - Finance Bill for 2020 adopted by parliament
On 19 December 2019, the parliament adopted the Finance Bill for 2020. According to the bill, the corporate income tax rate will be reduced from 33% to 31%. Previously 33% corporate tax rate was applicable for companies with revenues higher than EUR 250 million.

Greece - Tax Reform Bill gazetted
On 5 December 2019, the Tax Reform Bill was adopted by the parliament. The following changes were implemented:
   • The corporate income tax rate was reduced from 28% to 24% starting from FY2019.
   • Dividend withholding tax was reduced from 10% to 5% (for dividends distribution in 2020).
   • The participation exemption provisions are extended to include capital gains. Capital gains are exempt from corporate income tax at the level of Greek resident entities, provided that company hold at least 10% and shareholding lasted for at least 36 months.

Malaysia Labuan – increased tax rate for certain companies
On 18 December 2019, the Senate passed the Labuan Business Activity Tax Bill 2019. According to the amendments, a Labuan entity which does not comply with the substantial activity requirements will be taxed at the rate of 24% of its chargeable profits for that year of assessment.

Netherlands – Tax plan 2020 was adopted
On 12 December 2019, the Tax Plan 2020 was gazetted. The main amendments are the following.

1. The corporate income tax rate will be:

• for 2020: 16.5% on profits up to EUR 200,000, and 25% on the excess; and
• for 2021: 15% on profits up to EUR 200,000, and 21.7% on the excess.

   2. A conditional withholding tax will be introduced at a rate of 21.7% on interest and royalties flowing to low-tax jurisdictions, as well as in abusive situations, from 2021.
 
ANTI TAX AVOIDANCE

BEPS Action 13: OECD releases further guidance on CbC reporting
On 23 December 2019, the OECD/G20 Inclusive Framework on BEPS issued additional interpretative guidance on the implementation of CbC reporting. The Guidance provides tax administrations and multinational enterprises with additional instructions on the implementation of the CbC reporting rules.

Qatar - transfer pricing documentation requirements were implemented
New rules impose reqirements to file a master file and a local file according to the OECD guidance, provided that the gross amount of revenues of the resident entity exceeds a certain threshold to be determined by a decision of the General Tax Authority. At least one of the related parties should be resident outside Qatar. The deadline for submitting the local and master files is the same as that for filing the tax return.