Denmark: 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
See MoreDominican 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
See MoreChile: Government publishes Tax Reform Law
On 24 February 2020, Government published Law No. 21.210 in the Official Gazette and effects as from 1 January 2020. This Law was approved by the Senate on 29 January 2020. The tax reform Law includes: Corporate income tax The Law includes a
See MoreChile: Senate approves Tax Reform Bill
On 29 January 2020, the Senate approved a Tax Reform Bill. Once in force, the proposed measures will generally apply as from 1 January 2020, except the VAT requirements for digital services, which will be implemented three months after the law is
See MoreQatar publishes new regulations to amend income tax law
On 11 December 2019, Qatar published Executive regulations 39/2019 in the Official Gazette, introduced new Income Tax Law No. 24 of 2018. The new regulations are generally effective from 12 December 2019. Key features of the new regulations
See MoreUS: IRS issues final regulations on the base erosion and anti-abuse tax
On 2 December 2019, the Internal Revenue Service (IRS) issued final regulations and proposed regulations on the base erosion and anti-abuse tax. The Tax Cuts and Jobs Act (TCJA) made major changes to the tax law including revamping the U.S.
See MoreMexico implements economic package 2020
On 9 December 2019, Mexico has published a decree to implement economic package 2020 which was approved by Mexican Congress on 30 October 2019. This Decree will enter into force on January 1, 2020. The economic package consists of the following
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