Saudi Arabia issues circular on Force of Attraction rule in the Context of PE
The Saudi Arabian General Authority for Zakat and Tax (GAZT), in April 2021, published Circular No. 2104001, entitled Force of Attraction rule in the context of permanent establishment (pdf). The Circular confirms the GAZT’s approach to applying
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 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
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 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 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 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 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
See MoreDenmark publishes the Bill no. L 48 on international taxation
On 6 November 2019, the Danish Minister of Taxation published Bill no. L 48 on international taxation. The bill updated the existing PE (permanent establishment) rules, CFC rules and strengthen the Transfer pricing (TP) rules. PE rules: The
See MoreNew Zealand: Inland Revenue updates its compliance focus on MNEs
On 1 November 2019, the Inland Revenue has published a document setting out its compliance focus in respect of Multinational Enterprises (MNEs). The document aimed to make tax compliance more transparent for businesses and provide transparency and
See MoreColombia: MinHacienda issues decree on taxation of investment funds and PEs
On October 29, the Colombian Ministry of Finance and Public Credit (MinHacienda) has issued Decree 1973, which clarified measures regarding the taxation of private equity funds and collective investment funds and rules on the attribution of income
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