Peru submits a draft bill to Congress to ratify BEPS MLI
On 8 September 2022, a draft bill was submitted to the Peruvian Congress for the ratification of the multilateral convention to implement tax treaty related measures to prevent base erosion and profit shifting (MLI). Peru signed the convention on 27
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Ireland includes new countries on the DSTs guidance
On 7 September 2022, the Irish Revenue published an eBrief No. 168/22 on updated Tax and Duty Manual Part 04-06-03, which provides guidance on the tax deductibility of Digital Services Taxes (DSTs). The guidance was updated to include the
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OECD: Practical Guide on Capacity Building
On 7 September 2022 the OECD published a report on Tax Capacity Building: A Practical Guide to Developing and Advancing Tax Capacity Building Programmes. The report looks at considerations to be taken into account in formulating a tax capacity
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Argentina: MoE publishes new late tax payment and refund interest rates
On 23 August 2022, the Argentine Ministry of Economy published Resolution 559/2022, which provides new rates for late tax payments and reimbursement interest. The latest repeals Resolution 598/2019, which established rules for setting interest rates
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Taiwan: MOF exempts FINI on physical WHT statements
On 2 September 2022, the Ministry of Finance (MOF) of Taiwan issued a press release to provide an exemption for a Foreign Institutional Investor (FINI) in case of physical withholding tax (WHT) statements when applying for the reduced tax rate in
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Transfer Pricing Brief: September 2022
Australia Local file-General rule: On 9 August 2022, the Australian Taxation Office (ATO) updated guidance on the Local and Master file for 2022 along with instructions. The guidance applies to reporting periods beginning on or after 1
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OECD: Building Trust Between Tax Administrations and Large Businesses
On 5 September 2022 the OECD published a report on building trust between tax administrations and large businesses. The research forms part of the broader work undertaken by the OECD on tax morale, to encourage further global discussion. In
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South Africa: National Assembly approves BEPS MLI
On 31 August 2022, the South African National Assembly (NA) approved the Multilateral Convention to Implement Tax Treaty-related measures to prevent Base Erosion and Profit Shifting (MLI). The MLI will generally enter into force for a particular
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Malaysia: IRBM issues guidance on tax treatment of digital currency
On 26 August 2022, the Inland Revenue Board of Malaysia (IRBM) has published guidance on income tax treatment in respect of e-CT which includes general tax treatment of digital currencies or digital tokens. The Guidelines applies to any person that
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China: BEPS MLI in Force
On 1 September 2022, the Multilateral Convention to Implement Tax Treaty Related Measures to Prevent Base Erosion and Profit Shifting (MLI) entered into force for China. With regard to the double taxation agreements between China and other
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Taiwan: MOF exempts provisional income tax payments from January to June 2022
Recently, the Ministry of Finance of Taiwan provides an exemption on provisional income tax payments for the period January to June 2022. The exemption is provided for provisional income tax returns in September 2022 for companies affected by the
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IMF Report Considers Austria’s Fiscal Position
On 2 September 2022 the IMF published a report following the conclusion of discussions with Austria under Article IV of the IMF’s articles of agreement. The IMF report notes that Austria’s economy has recovered strongly from the problems
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OECD: Impact of Population Ageing on Government Revenue
On 30 August 2022 the OECD published a Fiscal Federalism paper dealing with the effect of population ageing on tax revenue across all levels of government. The study is part of a larger project examining the fiscal challenges of population ageing.
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Angola reduces WHT rate on services for nonresident legal entities
On 22 August 2022, Angola published Law no. 27/22 in the Official Gazette amending the Corporate Income Tax Code. Accordingly, the withholding tax (WHT) rate on services paid to non-residents has been reduced to 6.5% from 15%. The rate is effective
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US: Sixth Circuit affirms taxpayer not liable for penalty upon cancellation of APAs
On 25 August 2022, the U.S. Court of Appeals for the Sixth Circuit affirmed in part and reversed in part a decision of the U.S. tax court regarding the transfer pricing case of Eaton Corp. v. Commissioner. Facts of the case Eaton Corporation
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El Salvador: Legislative Assembly adopts tax amnesty program
On 24 August 2022, the Legislative Assembly of El Salvador approved tax amnesty program that allows taxpayers voluntarily come forward, accurately declare their income and pay any undeclared or underreported taxes. The El Salvador tax authorities
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US: IRS provides broad-based penalty relief for certain 2019 and 2020 returns
To help struggling taxpayers affected by the COVID-19 pandemic, on 24 August 2022, the Internal Revenue Service issued Notice 2022-36, which provides penalty relief to most people and businesses who file certain 2019 or 2020 returns late. The relief
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New Zealand extends R&D tax incentive due dates
On 26 Aug 2022, New Zealand’s Inland Revenue (IR) issued research and development (R&D) tax incentive updates due to the ongoing COVID-19 pandemic. The IR provides details on R&D tax incentive extensions, changes to claiming supporting
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