Ukraine: Parliament accepts changes to recently implemented BEPS legislation
On 17 December 2020, the Ukrainian Parliament has accepted a tax reform bill, which contains important changes to recently implemented BEPS legislation. The following important changes were introduced related to recently implemented BEPS and other
See MoreAustria: Parliament approves winter package due to COVID-19 pandemic
On 17 December 2020, the Parliament approved the COVID-19 Tax Measures Act. Recently, the Ministry of Finance has announced the draft winter package on tax measures for the coronavirus outbreak. The package includes the measures to introduce the
See MoreOECD: Implementation of transfer pricing for hard-to-value intangibles
On 16 December 2020 the OECD published information setting out the extent to which member countries of the Inclusive Framework have implemented the recommendations on hard to value intangibles (HTVI) drawn up as part of the OECD/G20 project on base
See MoreOECD: Transfer Pricing Implications of the Pandemic
On 18 December 2020 the OECD issued Guidance on the transfer pricing implications of the COVID-19 pandemic. This looks at the impact of the pandemic on areas of the transfer pricing analysis and APAs. Comparability analysis The pandemic and
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 MoreHungary: Parliament approves tax omnibus bill including CFC Rules
On 13 October 2020, the Hungarian parliament approved a Bill No. T/13258, to amend various taxation laws. The bill contains the following measures: Disallow company income tax exemptions to controlled foreign companies from EU blacklisted
See MoreSpain: Cabinet approves draft bill prevention and fight against tax fraud
On 13 October 2020, the Spanish Council of Ministers approved a draft law on prevention and fight against tax fraud. The law includes following measures: Decrease the cash payment limit to EUR 10,000 from EUR 15,000 for certain economic
See MoreAustralia: Guidance on Anti-abuse rules in tax treaties
On 12 October 2020, Australian taxation office (ATO) release new guidance about the general anti-abuse rules in any of Australia's tax treaties has been finalized and published. Law Administration Practice Statement PS LA 2020/2 Administering
See MorePoland: Council Ministers publishes draft bill amending CIT rules
On 16 September 2020, the Polish Council of Ministers published a draft bill amending the corporate income tax (CIT) rules to be in force from 1 January 2021. The bill includes the following tax measures; Limited partnerships in Poland are
See MoreOECD: Phase 3 Peer Review Reports on Country by Country Reporting
On 24 September 2020, the OECD published a compilation of Phase 3 peer review reports on Country by Country (CbC) Reporting under Action 13 of the action plan on base erosion and profit shifting (BEPS). The OECD/G20 Inclusive Framework on BEPS,
See MoreMexico: Executive Branch submits 2021 economic proposal to Congress
On 8 September 2020, the Mexican Executive Branch has submitted Economic Package for fiscal year 2021 including a proposal of Tax Reform. The proposed 2021 Tax Law clarifies income tax law, value-added tax (VAT) law, and federal tax code. Tax key
See MoreUS: IRS releases final regulations on interest expense deduction limitation
On 14 September 2020, the US IRS published the final regulations for the business interest expense deduction limitation published in the Federal Register. The final regulations vary slightly from the document released on IRS.gov on July 28,
See MoreNetherlands: Budget proposals for FY 2021
On 15 September 2020, the Dutch government published the budget proposals for fiscal year 2021. The proposals are currently subject to the review and discussions by the Dutch Parliament and as such may be subject to amendments. The final version of
See MoreSweden proposes to deny deductions for interest expenses regarding debts to EU blacklist countries
On 3 September 2020, the Swedish Government has announced to deny deductions for interest expenses regarding debts to EU blacklist countries. The EU's work against tax planning and harmful tax competition has been going on for a long
See MoreMalta: Commissioner for Revenue issues ATAD implementation Guidelines
On 31 August 2020, the Maltese Commissioner for Revenue has issued Guidelines in relation to the Anti-Tax Avoidance Directives Implementation Regulations (ATAD) on its website. The guidelines on the ATAD Implementation Regulations were issued in
See MoreUkraine: SFS releases guidance letter on new CFC rules
On 17 August 2020, the Ukraine State Fiscal Service (SFS) has issued a guidance letter 3380/IPK/99-00-05-05-02-09, which clarifies the taxation of profits of controlled foreign companies (CFCs). In Ukraine, the CFC rule will be applicable from 1
See MoreChile: SII publishes a Letter regarding thin capitalization rules
On 31 July 2020, the Chilean tax Authority (SII) published a Letter Ruling No. 1475 of 31 July 2020, which addresses whether interest payments on a loan agreement concluded in 2014 between a Chilean resident company and a non-resident related party
See MoreUS: IRS publishes revised practice unit on dividends or interest from a related CFC
On 29 July 2020, the U.S. IRS published a revised international practice unit on the Receipt of Dividends or Interest from a Related CFC. The practice unit was revised to include the extension of the IRC 954(c)(6) look through rule for CFCs with
See More