UK: Consultation on securitisation tax regime
On 23 March 2021 the UK government issued a consultation paper on the reform of the taxation of securitisation companies. Securitisation is used for the purpose of raising finance on the capital markets through the issue of asset-backed
See MoreSingapore updates guidance on tax residence rules of a company and PE
The Inland Revenue Authority of Singapore (IRAS) issued updated guidance on the tax residence status of companies and permanent establishments (PE) in light of the Covid-19 pandemic. Tax Residence Status of a Company Where a company is not
See MoreAustralia: ATO introduces guidance on Covid-19 and PE
The Australian Taxation Office (ATO) updated guidance on whether the presence of employees in Australia, due to the impacts of Covid-19, may create a permanent establishment (PE). The updated guidance states that the ATO will not apply
See MoreFinland: Tax Authority publishes overview of tax changes for 2021
On 16 December 2020, the tax authority of Finland has released an overview of tax changes for 2021. The changes related to corporate tax matters are summarized below: The final losses of a subsidiary located in another EEA state be taken into
See MoreUkraine: 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 MoreDenmark: Parliament adopts a Law regarding transfer pricing
On 3 December 2020, the Parliament adopted the draft Bill No. L 28, which proposes to implement the OECD's recommendations on permanent establishment, so that the Danish rules are brought into line with the latest international standards. The
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Dominican Republic: DGII implements tax relief for facilitating tax compliances
On 8 October 2020, the Dominican Tax Authority (DGII) published General Rule 05-20, which provides implementation of tax amnesty and facility on tax compliances. According to the tax amnesty measures, taxpayers will be allowed to pay an amount
See MoreCyprus: Tax authority issues directive implementing guidelines on tax residency
On 27 October 2020, the Cyprus Tax Department (CTD) issued Implementing Directive No. 04/2020, which clarifies the application of the Cyprus Income Tax Law provisions (Article 2) related to tax residency and PE during the COVID-19 crisis. The
See MoreGreece: Supreme Court makes a decision in favour of an informal company
On 23 October 2020, the Supreme Court has made a decision that an informal company cannot be subject to income tax provided by law 2238/1994. An informal company is a company that does not have legal personality because it lacks the constituent
See MorePeru issues resolution on international merger operation between two non-domiciled companies
On 6 October 2020, the Peruvian tax authorities (SUNAT) issued Resolution No. 061-2020-SUNAT / 7T0000 Official Website, through which the following has been concluded: The permanent establishment must maintain the same RUC number and notify
See MoreOman: Sultan amends Income Tax Law
On 14 September 2020, Mr. Haitham Bin Tarik, the Sultan of Oman issued Royal Decree No. 118/2020, which amended certain provisions of the Income Tax Law (ITL). The major changes are following: For tax years starting on or after 1 January 2020,
See MoreSingapore: IRAS publishes e-Tax Guide for Variable Capital Companies
The Inland Revenue Authority of Singapore has issued an e-Tax guide about tax framework for Variable Capital Companies (VCC). The e-Tax Guide explains the tax framework for variable capital companies (VCCs). The VCC is a new corporate structure
See MoreCanada: CRA further extends the application periods regarding international tax issues
On 31 August 2020, the Canadian Revenue Agency published a Guidance in their website to announce further extension of the application period until 30 September 2020 on various international tax issues arising due to COVID-19. This Guide includes
See MoreColombia issues decree on taxation of investment funds and PEs
On 19 July 2020, the Colombia Ministry of Finance and Public Credit has issued Decree 1054 of 2020, which determines the scope in tax matters of the concepts taxation of investment funds and (permanent establishments) PEs. The Decree was issued
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 MoreOECD: Tax issues for cross border workers during the COVID-19 crisis
On 7 April 2020 the OECD published on its website guidance on tax issues relating to cross-border workers during the crisis. As a result of travel restrictions and quarantine requirements many cross-border workers cannot go to the country where
See MoreUK: Finance Bill 2020 Published
On 19 March 2020 the UK introduced the Finance Bill 2020 into parliament. In addition to implementing the changes to rates and allowances included in the budget announcements the Bill introduces the digital services tax. The measures in the Finance
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
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