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Approved Changes (5)


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Belgium Sets Tax Return Deadlines for 2019 Tax Year

The Belgian Federal Public Service (SPF) Finance has provided the tax return deadlines for the 2019 tax year (years ending 31 December 2018 to 30 December 2019). Under standard rules, returns are due one month after the approval of the financial statements during the annual statutory general meeting, but no later than six months after the end of the company's financial year. However, this is typically extended, including for tax returns due for the 2019 tax year. For years ending 31 December 2018, the tax return deadline has been set at 26 September 2019. The deadline applies for both electronic and paper filers.

Click the following link for the table of deadlines based on the year-end date and the month of the general meeting.



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Colombia Clarifies Interest on Loans for the Acquisition of Shares is Not Deductible

The Colombian Tax Authority (DIAN) recently issued a ruling concerning whether interest payments on loans obtained for the acquisition of shares are deductible. The ruling notes that expenses are generally deductible as long as they have a cause-effect relationship with income-producing activities and are necessary and proportionate. In respect of interest payments on loans for the acquisition of shares, DIAN does not consider that such payments meet those conditions and therefore the payments are not deductible. However, the interest paid can be included as part of the cost of acquiring the shares.



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India-U.S. Agreement on Exchange of CbC Reports Enters into Force

The IRS reported that the India-U.S. agreement on the exchange of country-by-country reports entered into force and applies from 29 April 2019.

The agreement was signed based on article 28 (exchange of information and administrative assistance) of the India-US income tax treaty. The Indian and U.S. competent authorities signed a competent authority arrangement on the exchange of CbC reports, which also applies from 29 April 2019.



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Luxembourg Publishes Updated List of Partner Jurisdictions for CRS Exchange

The Luxembourg Official Gazette of 17 May 2019 published the updated list of partner jurisdictions with which Luxembourg may automatically exchange financial account information for the year 2019 under the OECD CRS exchange.

The Notice and list of partner jurisdictions are accessible here (in French)



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Ukraine VAT Obligations for Advance Payments in Foreign Currency

The Ukraine State Fiscal Service issued a guidance letter on 19 April 2019 to clarify the value added tax (VAT) obligations of a resident service supplier for advance payments received in foreign currency from a non-resident for services supplied in Ukraine. Because the place of supply of the services is Ukraine, the payments are subject to VAT. The VAT amount due must be calculated on the date the payments are received in the resident supplier's bank account, with the foreign currency amount converted to Ukrainian hryvnia based on the official exchange rate of the National Bank of Ukraine to determine the tax base.

Treaty Changes (3)


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Armenia Approves Pending Tax Treaty with Demark

On 16 May 2019, the Armenian government approved the law for the ratification of the pending income and capital tax treaty with Denmark. The treaty, signed 14 March 2018 (previous coverage), is the first of its kind between the two countries and will enter into force the day following the exchange of the ratification instruments and will apply from 1 January of the year following its entry into force.



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Japan Parliament Approves Pending Tax Treaties with Colombia, Croatia, Ecuador, and Spain

The Japanese Diet (parliament) has reportedly approved the laws for the ratification of the following tax treaties:

  • The income tax treaty with Colombia, which was signed on 19 December 2018 (previous coverage);
  • The income tax treaty with Croatia, which was signed on 19 October 2018 (previous coverage);
  • The income tax treaty with Ecuador, which was signed on 15 January 2019 (previous coverage); and
  • The new income tax treaty with Spain, which was signed on 16 October 2018 (previous coverage).

The treaty with Spain will enter into force on the first day of the third month following the exchange of the ratification instruments, while the other three treaties will enter into force 30 days after the ratification instruments are exchanged. All four tax treaties will generally apply from 1 January of the year following their entry into force.



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SSA between Moldova and Russia under Negotiation

According to a release from Moldova's Ministry of Health, Labour, and Social Protection, officials from Moldova and Russia met on 14 May 2019 for the first round of negotiations for a social security agreement. Any resulting agreement will be the first of its kind between the two countries and must be finalized, signed, and ratified before entering into force.


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