Ireland: Finance Ministry declares for a feedback statement on ATAD anti-hybrid rule
On 2 July 2021, the Finance Minister, Paschal Donohoe TD, launched a Feedback Statement on the Anti-reverse hybrid rule. The anti-hybrid rules are largely contained in ATAD2, which extended the basic anti-hybrid provisions of the first ATAD and
See MoreDenmark: OECD publishes latest MLI position on arbitration reservation
On 29 June 2021, the OECD published a document, which contains the consolidated list of reservations and notifications made by the Kingdom of Denmark upon deposit of the instrument of ratification pursuant to Articles 28(5) and 29(1) of the
See MoreDenmark: Parliament approves ATAD amendments to CFC rules
On 3 June 2021, the Danish Parliament approved a Bill L 89 to amend the controlled foreign company (CFC) rules with the purpose of bringing them in line with the EU Anti-Tax Avoidance Directive (ATAD). The major mechanism in the Danish CFC rules
See MorePoland: MOF announces a proposal to change the transfer pricing regulation
On 28 June 2021, Poland Ministry of Finance issued a plans for taxpayer-friendly amendments to the transfer pricing regulations. The following measures have been proposed under this plan. Cancellation on the preparation of transfer pricing
See MoreTurkey amends the decision on government aid in investments
On 28 June 2021, Turkey has published Presidential Decision No. 4191 in the Official Gazette. With Presidential Decision No. 4191, Amendments have been made in the Decision No. 2012/3305 on State Aids in Investments. Important changes were made in
See MoreUS: Treasury, IRS extend safe harbor for renewable energy projects
On 29 June 2021, the Department of the Treasury and the Internal Revenue Service issued guidance for taxpayers developing renewable energy projects to address delays related to the COVID-19 pandemic. In prior IRS notices, the Treasury
See MoreUS: IRS releases draft instructions Schedules K-2 and K-3 for international tax reporting
On 30 June 2021, the Treasury and the IRS released early draft instructions for the Schedules K-2 and K-3 for Forms 1065, 1120-S, and 8865 for tax year 2021 (filing season 2022). The early release drafts of the instructions provide a preview
See MoreOECD: Statement on the tax challenges of the digital economy
On 1 July 2021 the OECD released a Statement in relation to the work on the tax challenges of the digital economy. The OECD reported that 130 countries and jurisdictions are taking part in the two-pillar reform to the international tax system
See MoreSouth Africa: SARS publishes list of jurisdiction with effective CbC report exchange agreements
The South African Revenue Service (SARS) published a latest list of jurisdictions. These listed jurisdictions have CbC report exchange agreements with South Africa from 22 June 2021. The lists are intended to assist members of MNE Groups tax
See MoreIceland publishes a law on new penalties for transfer pricing documentation
On 15 June 2021, Iceland published Law 61/2021 in the Official Gazette introducing new rules for the imposition of fines on taxpayers who fail to comply with transfer pricing documentation requirements for related party transactions, whether
See MoreUK: OTS to Consider Changing the Tax Year End
On 8 June 2021 it was reported that the UK’s Office for Tax Simplification (OTS) is to begin a review of the costs and benefits of moving the UK’s tax year end from 5 April to either 31 March or 31 December. The OTS has issued a review
See MoreUK: HMRC investigates the use of business support schemes
It was reported on 28 June 2021 that the UK tax authority HMRC has begun around 13,000 investigations concerning the use of the UK coronavirus business support schemes. The investigations relate to fraud and other breaches of rules. It is
See MoreMalaysia: BEPS MLI enters into force
On 29 June 2021, OECD has published the updated position of signatories’ countries regarding the Multilateral Convention to Implement Tax Treaty Related Measures to Prevent Base Erosion and Profit Shifting (MLI). Accordingly, the MLI entered into
See MorePoland: MOF further defers the WHT collection system to 31 December 2021
On 25 June 2021, the Polish Ministry of Finance has published a decree providing further postponed the introduction of the withholding tax pay and refund system until 31 December 2021. The obligation was originally deferred until the end of June
See MoreCroatia: BEPS MLI enters into force
On 29 June 2021, OECD has published the updated position of signatories’ countries regarding the Multilateral Convention to Implement Tax Treaty Related Measures to Prevent Base Erosion and Profit Shifting (MLI). Accordingly, the MLI enters into
See MoreCanada: CRA replaces and abolishes a Circular regarding MAP
On 1 June 2021, the Canada Revenue Agency (CRA) published Information Circular IC71-17R6, which replaces and cancels Information Circular 71-17R5 dated January 1, 2005. This Circular describes several changes related to MAP. MAP filing
See MoreTaiwan: MOF issues Decree on cross-border bilateral, multilateral APAs under MAP
On 24 June 2021, the Ministry of Finance issued a Decree which stipulates that when tax collection authorities negotiate cross-border bilateral or multilateral advance pricing arrangements (APAs) (hereinafter referred to as "BAPAs") with the
See MoreUK: Employee Share Scheme Statistics for 2019/20
On 24 June 2021 the UK published the 2019/2020 statistics on employee share schemes. Employee Share Schemes (ESS) are available to companies that want to award shares directly to their employees or to grant them options to buy shares. There
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