Qatar amends income tax law
On 2 February 2023, Qatar published Law No.11 of 2022 amending several provisions of the Income Tax Law No. 24 of 2018 in the official Gazette. The effective date of the amendments is also 2 February 2023. The amendments are generally effective from
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Ireland: Revenue issues guidance on attribution of profits to a branch
On 7 September 2022, the Irish Revenue published an eBrief No. 166/22 on the attribution of profits to a branch. Accordingly, Tax and Duty Manual Part 02-02-04a has been issued to provide an overview and guidance in relation to the attribution of
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Austria: MOF Updates Guidance on COVID-19 treaty Issues
On 20 June 2022, the Ministry of Finance published a Circular (no. 2022-0.433.029 of 17 June 2022) clarifying various tax treaty issues that have arisen due to the COVID-19 pandemic, including permanent establishments(PE) and the application of the
See MoreUkraine: SFS clarifies PE rule for non-residents for tax purposes
On 12 October 2021, the Ukrainian State Fiscal Service (SFS) has clarified that a non-resident company considers as a permanent establishment (PE) if the company enters into agreements and carries out economic activities in Ukraine on its own
See MoreTaiwan announces the amendments to the tax treaty rules and PE rules
On 12 August 2021, Taiwan’s Ministry of Finance has announced the amendments to the “Regulations Governing Application of Agreements for the Avoidance of Double Taxation with Respect to Taxes on Income”. The amended regulations have come into
See MoreTanzania: Revenue Authority publishes Finance Act 2021
On 30 June 2021, the Revenue Authority Officially published the Finance Act 2021. Some of the tax measures, which generally applies from 1 July 2021 are given below: Permanent establishment According to Finance Act 2021, the definition of the
See MoreGreece: Tax administration issues a Circular on tax residency and PE rules
On 25 June 2021, the Tax Administration issued a Circular E. 2130 /2021, which includes additional guidelines in relation to the application of domestic law and double tax treaty provisions with respect to tax residency and permanent establishment
See MoreTanzania: National Assembly publishes Finance Bill 2021
On 12 June 2021, the National Assembly published the Finance Bill 2021, which contains the measures of Budget for 2021/22. This Act shall come into operation on 1 July 2021. The Bill proposed the following things: The definition of the term
See MoreBelarus: Tax and Duties Ministry clarifies the taxation of PEs in Belarus
On 29 April 2021, the Tax and Duties Ministry of the Republic of Belarus has issued Guidance Letter No. 4-2-15/00981 to clarify the taxation of foreign organizations operating in the territory of the Republic of Belarus through permanent
See MoreSaudi 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
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