The proposed amendment to the Income Taxes Act (included in the government package of tax law amendments), whose primary objective is to implement the EU Anti Tax Avoidance Directive – ATAD from 1 January 2019, is awaiting debate in the Chamber of Deputies in the first reading. A question mark is therefore beginning to appear regarding whether or not the proposed amendment will be able to go through the whole legislative process by the year end.
Given the complexity of the new provisions of the implemented directive (especially the definition and calculation of deductibility of interest and financial expenses arising from loans, CFC rules etc.), the Financial Administration is working to prepare methodology to describe the procedures according to the new provisions and definitions in more detail including illustrations on specific examples. At present it is unclear what form the methodology will have or when the Financial Administration should publish it.
The article is part of dReport – October 2018, Tax news; Grants and investment Incentives.
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