South Africa: Court makes a decision regarding TP methods
On 7 January 2021, in the case of: ABC (Pty) Ltd v. Commissioner (IT 14305) ZATC 1, the South African Court upheld a transfer pricing adjustment for a taxpayer that failed to have transfer pricing documentation to support the arm’s
See MoreOECD: Forum on Tax Administration Agrees Action on Administrative Challenges
On 8 December 2020 representatives of the members of the OECD’s Forum on Tax Administration (FTA) agreed on an agenda for 2021 focusing on tax certainty and digital enhancement of tax administration. The FTA is a global forum on tax
See MoreBulgaria: Government imposes penalty for late application of tax treaty relief
On 18 November 2020, parliament passed amendments to the Tax and Social Security Procedure Code at first reading, which aims to ensure the payment of withholding tax on cross-border payments and the effectiveness of tax control in the event of
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UK: Updated Statistics on Transfer Pricing and Diverted Profits Tax
On 12 November 2020 HMRC published updated statistics relating to transfer pricing and the diverted profits tax for 2019/20 (the year to 31 March 2020). In 2019/20 a total of 125 transfer pricing enquiries were settled, with an average
See MoreECJ: Ruling on Transfer Pricing Treatment of Bank Transfers Between Branch and Parent
On 8 October 2020 the European Court of Justice (ECJ) ruled on Romania’s transfer pricing rules in relation to bank transfers from a branch to a head office that is located in another EU Member State. Impresa Pizzarotti concluded two loan
See MoreOECD: Economic Survey of UK
On 14 October 2020 the OECD published on its website its economic survey of the UK. The outlook for the UK is uncertain with the combination of Brexit and the COVID-19 crisis. Since July 2020 the UK has begun a new phase of support for business
See MoreCzech Republic: Supreme Court makes a decision regarding transfer pricing issues
Recently, the Supreme Administrative Court has issued a landmark decision for companies that have incentives to invest in older systems. The court confirmed that failure to meet the condition not to increase the tax base for calculating tax relief
See MoreDenmark: National tax court clarifies TP documentation rules for intergroup companies
On 24 September 2020, the Danish Tax Administration published a Decision No. SKM2020.387.LSR, clarifying the transfer pricing documentation requirements for a change of business structure within a group company. The case concerns a Danish
See MoreUS: Final Withholding Regulations on Transfer of Partnership Interest by Foreign Partner
On 7 October 2020, the IRS issued final regulations on the withholding rules for transfers of partnership interests by foreign transferors. A gain on the sale or disposition by a non-US partner of an interest in a partnership that engaged in a
See MoreUK: Statistics on Research and Development Tax Relief
On 30 September 2020 HMRC published the statistics for claims for research and development (R&D) tax relief in the UK. By monitoring tax relief schemes HMRC can examine the level of use of the schemes and gain some insight into the
See MoreUK: Statistics on Patent Box Tax Relief
The patent box legislation allows companies in the UK to apply a lower corporation tax rate to profits earned from qualifying patented inventions and specified equivalent types of intellectual property. The relief was first introduced from 1 April
See MoreEU: Sectoral Policies for Climate Change Mitigation
On 16 September 2016 the EU published a departmental paper entitled Sectoral Policies for Climate Change Mitigation in the EU. The paper examines climate mitigation policy in five sectors that in aggregate account for 95% of greenhouse gas
See MoreCanada: The Tax Court makes a decision in a case regarding transfer pricing dispute
On 27 August 2020, the Tax Court of Canada made a decision in a case, Canada vs AgraCity Ltd. and Saskatchewan Ltd., in favor of Candian company AgraCity Ltd. and related company, Saskatchewan Ltd. The AgraCity Canada had entered into a Services
See MoreWorld Bank: Vietnam must boost new drivers of growth
On 30 July 2020 the World Bank issued an economic update entitled What will be the new normal for Vietnam: the economic impact of COVID-19?. Vietnam has been successfully fighting the COVID-19 crisis but GDP growth has suffered a fall of almost
See MoreUK: Statistics on creative industries tax relief
HMRC published updated statistics for creative industries tax relief for 2019/20 on 13 August 2020, showing that GBP 1.11 billion was paid out in tax relief for creative industries in 2019/20. Almost half the relief given related to film tax relief
See MoreUK: Consultation on Extension of R&D Tax Credits to Data and Cloud Computing
On 21 July 2020 the UK government launched a consultation on extending research and development (R&D) tax credits to costs relating to data and cloud computing. Comments are invited by 13 October 2020. R&D tax credits support innovative
See MoreUK: Amendments to the Restriction on the Tax Deduction for Interest
On 21 July 2020 the UK published draft legislation to amend the limitation on the interest deduction for corporation tax. This would be part of the Finance Bill for 2020/21. The rules to limit the corporation tax deduction for interest were
See MoreCanada: Federal Court of Appeal makes a decision on a case regarding GAAR
On 5 May 2020, the Federal Court of Appeal has made a decision on a case entitled, “2018 TCC 187”, which was against the tax authorities, but in favor of the Tax Court of Canada's decision or the taxpayer. The Federal Court finds that the loss
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