US: 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 MoreAngola 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
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