Angola amends the General Tax Code
On 9 July 2020, Angola has published Law no. 21/20 in the Official Gazette amending to the General Tax Code. Among the changes introduced, the following stand out: introduced a general anti-abuse rule (GAAR) allowing the tax authorities to
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 MoreRussia aims to introduce fixed tax of RUB 5 million on CFC income
The government of Russia is planning several tax measures to be introduced in 2021 including an increased 15% tax rate applies on high-earning individuals and reduced 3% tax rate on Information Technology enterprises. In addition to these
See MorePlatform for Collaboration on Tax: Draft Toolkit on Tax Treaty Negotiations
The Platform for Collaboration on Tax (PCT) has issued a draft toolkit on tax treaty negotiations. The period for feedback from interested parties is 29 June 2020 to 10 September 2020. The PCT was set up by the OECD, IMF, World Bank and UN to
See MoreAustralia: Guidance on the Impact of the COVID-19 Crisis on Transfer Pricing Arrangements
On 19 June 2020 the Australian Taxation Office (ATO) posted to its website guidance entitled COVID-19 economic impacts on transfer pricing arrangements. This sets out guidance for taxpayers affected by COVID-19 who are preparing transfer pricing
See MoreColombia modifies thin capitalization rule
On 29 May 2020, the Government of Colombia has issued Decree 761 of 2020, through which the thin capitalization rule established in article 118-1 of the Tax Statute is modified. The decree was substantially ratified by the Law 2010 of 2019 as Law
See MoreUkraine: President signs law to implement BEPS and other provisions
On 21 May 2020, the President of Ukraine signed Law No. 466-IX (Draft Law No.1210) “On Amendments to the Tax Code of Ukraine on Improvement of Tax Administration, Elimination of Technical and Logical Inconsistencies in Tax Legislation", which was
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
See MoreUS: Tax court ruled in favor of the IRS for Whirlpool vs Commissioner case
On 5 May 2020, the US tax court made a decision in favor of the IRS a case involving the Whirlpool Financial Corp. and related foreign affiliate corporations. The Court upheld the Internal Revenue Service's (IRS) application of the Subpart F
See MoreDenmark: President announces to postpone a Bill for amending CFC rules
On 15 April 2020, the Prime Minister informed the president of the parliament that some of proposed legislation need to be postponed during COVID-19 pandemic. One of the proposed legislation is Bill L48, which provides the transpose in existing CFC
See MorePlatform for Collaboration on Tax Launches Website
A new website has been launched by the Platform for Collaboration on Tax (PCT). The PCT is a joint initiative of the International Monetary Fund (IMF), the Organisation for Economic Co-operation and Development (OECD), the United Nations (UN), and
See MoreLuxembourg: Tax Authority issues new guidance on CFC rules
On 4 March 2020, the Luxembourg Tax Authority has issued Circular n°164ter/1 on the controlled foreign corporation (CFC) rules. Luxembourg enacted CFC rules as part of the implementation of the EU Anti-Tax Avoidance Directive (ATAD) on 21 December
See MoreSerbia: Ministry of Finance publishes safe harbor interest rates for 2020
The Serbian ministry of finance has published the Rulebook on arm’s length interest rates that are applicable for 2020, which apply to interest rates on loans and credits between associated parties. The Rulebook was published in the Official
See MorePeru: SUNAT provides a list of high-risk tax planning schemes regarding GAAR
On 5 February 2020, the Peruvian Tax Administration (SUNAT) has published first version of the list of high-risk tax planning schemes regarding General Anti-Avoidance Rule (GAAR). The list contains the following five tax planning
See MoreDominican Republic: DGII publishes list of territories not considered tax heavens
The Directorate General of Internal Revenue (DGII) issued Notice 10-20 regarding an updated list of States that are not considered tax heaven or preferential tax regimes. The list includes the following territories: Antigua and Barbuda,
See MoreColombia: DIAN issues new guidelines for GAAR
On 15 January 2020, Colombian tax authority (DIAN) has published Executive Order No. 4 of 7 January 2020 in the official gazette where DIAN clarifies the application of General Anti-Avoidance Rule (GAAR). The GAAR provisions are contained in
See MoreRomania enacts EU mandatory disclosure regime (DAC6)
On 28 January 2020, the Government of Romania has published Ordinance no. 5 of 28 January 2020 in the Official Gazette for the implementation of Council Directive (EU) 2018/822 of 25 May 2018 (DAC6) on reportable cross-border tax planning
See MoreFrance: Tax authority publishes guidelines on the new provisions on abuse of law
On 31 January 2020, the tax authority published guidelines regarding the application of the new general anti-abuse rules (GAAR). This guide provides an extension of Article 6 of the EU Anti-Tax Avoidance Directive 2016/1164. It may also apply in
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