ECJ: Ruling on Transfer Pricing Treatment of Bank Transfers Between Branch and Parent
On 8 October 2020 the European Court of Justice (ECJ) ruled on Romania’s transfer pricing rules in relation to bank transfers from a branch to a head office that is located in another EU Member State. Impresa Pizzarotti concluded two loan
See MoreCzech Republic: Deputies agrees with the postponement of the electronic registration
On 16 October 2020, the deputies approved the proposal of the Ministry of Finance to postpone all four phases of the electronic registration of sales until 1 January 2023. The amendment to the Act on the Registration of Sales is now heading to the
See MoreTurkey: Government submits bill to parliament for the corporate tax cut
On 16 October 2020, The Turkish Government has submitted a bill to reduce the Corporate Income Tax (CIT) rate to lower the corporate tax by up to 5%. As from 1 January 2018, the corporate income tax rate for all companies is 22% (applicable for
See MoreOECD: Ageing and Fiscal Challenges Across Levels of Government
A paper contributing to OECD Fiscal Federalism Studies published on 27 October 2020 looks at the fiscal challenges across levels of government resulting from an ageing population. Personal Tax Revenue and an Ageing Population Some tax systems
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 MoreOECD: Economic Survey of UK
On 14 October 2020 the OECD published on its website its economic survey of the UK. The outlook for the UK is uncertain with the combination of Brexit and the COVID-19 crisis. Since July 2020 the UK has begun a new phase of support for business
See MoreQatar introduces new process for tax filing
The General Tax Authority (GTA) launched a new online tax administration system called the Dhareeba portal in October 2020 and the process for making submissions via the previous system is no longer effective. As a result, the previous process used
See MoreLuxembourg: Finance Minister presents draft budget law for 2021
On 14 October 2020, Luxembourg’s Finance Minister has presented the draft budget law 2020 to the Parliament. There are no measures regarding major tax reform or an increase in the tax rate in the draft budget law. The draft budget laws contain a
See MoreHungary: Parliament approves tax omnibus bill including CFC Rules
On 13 October 2020, the Hungarian parliament approved a Bill No. T/13258, to amend various taxation laws. The bill contains the following measures: Disallow company income tax exemptions to controlled foreign companies from EU blacklisted
See MoreUruguay extends estimated tax payment deadline
On 14 October 2020, the tax Authority of Uruguay published Resolution No. 1.898/020, extending the deadline for making estimated tax payments of corporate income tax (CIT), net wealth tax and corporation control tax to December 2020
See MoreUruguay declares tax exemption for software development services
The tax authority of Uruguay has issued Resolution No. 1716 to exempt corporate tax for income from software development services. Particularly, the tax authority permitted taxpayers to include, in their expenses and direct costs incurred in
See MoreSpain: Cabinet approves draft bill prevention and fight against tax fraud
On 13 October 2020, the Spanish Council of Ministers approved a draft law on prevention and fight against tax fraud. The law includes following measures: Decrease the cash payment limit to EUR 10,000 from EUR 15,000 for certain economic
See MoreCzech Republic: Supreme Court makes a decision regarding transfer pricing issues
Recently, the Supreme Administrative Court has issued a landmark decision for companies that have incentives to invest in older systems. The court confirmed that failure to meet the condition not to increase the tax base for calculating tax relief
See MoreOECD: Economic Impact of Pillar One and Pillar Two
At a presentation on 12 October 2020 introducing Blueprint reports on Pillar 1 and Pillar 2 of the proposals on taxation of the digital economy, the OECD presented an economic impact analysis of the proposals. Pillar One Pillar One would
See MoreSaudi Arabia: GAZT extends tax relief measures up to 31 December 2020
On 6 October 2020, the General Authority of Zakat and Tax (GAZT) of Saudi Arabia has issued a press release, through which they cancel the fines and exemption from financial penalties for taxpayers until 31 December 2020 in response to the
See MoreOman extends relief provisions for late payment and late filing of tax returns
The tax authority of Oman declared extensions of certain tax relief measures due to the Covid-19 Outbreak. Previously, in response to the pandemic tax authority has granted relief from the imposition of interest for late payment of tax or late
See MoreCzech Republic: Finance Ministry declares the extension of COVID-19 tax relief
On 14 October 2020, the Finance Ministry announced that a large liberation packages are extended in response to coronavirus pandemic. The package includes delay of tax payments by companies whose primary activity falls into an area targeted by the
See MoreDenmark: National tax court clarifies TP documentation rules for intergroup companies
On 24 September 2020, the Danish Tax Administration published a Decision No. SKM2020.387.LSR, clarifying the transfer pricing documentation requirements for a change of business structure within a group company. The case concerns a Danish
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