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Newsletter KR Group 04/2018

In this edition:

  • Deadlines for the preparation of transfer pricing documentation deferred.
    On 15 March The Ordinance of the Minister of Finance of 14 March 2018 on the Extension of Deadlines for the Performance of Certain Duties Related to Transfer Pricing Documentation became effective (Journal of Laws, item 555).
  • General Ruling of the Minister of Finance on Transfer Pricing Obligations.
    Since 1 January 2017 the obligation to prepare transfer pricing documentation has been subject to verification pursuant to the new phrasing of article 9a of the Corporate Income Tax Act. However, upon publishing the new regulations, some controversies concerning their substance and its possible interpretations arose.
  • Taking up Capital Shares and the Obligation to Prepare Transfer Pricing Documentation.
    An individual tax ruling of the Head of the National Revenue Information confirms the Ministry’s position on the obligation to prepare tax documentation in situation when a taxpayer takes up shares issued upon creating a subsidiary in exchange for a cash contribution and when subsequent increases in the share capital of the company are performed.
  • Cash Contributions and the Creation of Revenue.
    On 1 January 2018 article 12, paragraph 1, subparagraph 7 of the CIT Act was amended. Removing the phrase “(…) in the event that a non-cash contribution to a company or a co-operative society is made in a form other than an enterprise or an organized part thereof” from the article has raised considerable doubts among taxpayers.
  • New Amendment to VAT Law – the relevance of proposed regulatory changes.
    On 27 February the website of the Government Legislation Centre featured a Draft Bill Amending the VAT Act and Certain Other Acts dated 13 February 2018. The latest amendments are to serve as the next step taken towards closing off the loopholes in the VAT system. Additionally, they are to clarify some particulars concerning the measures that have already been taken to that end.

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