Australia: 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 MoreLuxembourg Parliament approves Bill on the deduction of interest and royalties expenses
On 28 January 2021, the Luxembourg Parliament has approved Bill No. 7547 introducing a non-deductibility of interest or royalties paid to associate enterprises established in countries that are “blacklisted” as being “non-cooperative” for
See MoreOECD: International Tax Cooperation to Regulate Globalisation
On 1 February 2021 the OECD Secretary General published a blog post entitled A Turning Point for Tax: International co-operation for better regulation of globalisation. The note is based on the speech given by the Secretary General at the opening
See MoreBelgium postpones DAC6 reporting deadline
On 28 January 2021, the Belgian Ministry of Finance has declared that due to the Covid-19 pandemic the Belgian tax authority will be postponing its reporting deadline without late submission penalties. The reporting deadline for historical
See MoreUruguay extends CbC reporting deadline to 28 February 2021
On 19 January 2021, Uruguay's Directorate General of Taxation (DGI) has published Resolution No. 075/2021 regarding the extension of the Country-by-Country (CbC) reporting deadline to 28 February 2021 for reporting fiscal years ending between 1
See MoreSwitzerland declares safe harbor interest rates
The Federal Tax Administration of Switzerland has published two separate circulars regarding safe harbor interest rate limits applicable to shareholder and related party loans in 2021. The rates may vary depend on whether the financing is in Swiss
See MoreMalaysia: IRBM reduces documentation submission timeline on request
On 2 February 2021, the Inland Revenue Board of Malaysia (IRBM) updated its transfer pricing guidelines including new guidance on submission of transfer pricing documentation and penalties. With the introduction of Section 113B of the ITA1967 which
See MoreLuxembourg updates the list of jurisdictions for exchanging CbC reports
On 26 January 2021, the Luxembourg Ministry of Finance published Grand-Ducal Regulation of 22 January 2021 in the Official Gazette amending Grand-Ducal Regulation of 13 February 2018. The Regulation updates the list of jurisdictions for
See MoreOECD: Use of Energy Taxes to Strengthen Developing Country Finances
On 25 January 2021 the OECD issued a document entitled Taxing Energy Use for Sustainable Development: Opportunities for energy tax and subsidy reforms in selected developing and emerging economies. The report looks at energy taxation in a sample
See MoreCyprus extends the deadline for the submission of DAC6 to 31 March 2021
On 3 February 2021, the Cyprus Tax Department has issued a notice regarding the extension to submission of DAC6. The Tax Department informs that the Directive is expected to be incorporated into the Cypriot legislation within the current month.
See MoreSweden applies the so-called “Sunday rule” for DAC6 reporting deadlines
Recently, the Swedish Tax Agency has updated guidance on reportable arrangements (DAC6) reporting deadlines. The Tax Agency confirms that the so-called “Sunday rule” applies for DAC6 reporting deadlines. If the reporting deadline falls on a
See MoreSouth Africa: Government Officially publishes 2020 Tax Amendment Acts
On 20 January 2021, the Treasury Department Officially published the 2020 Tax Amendment Acts. The following Amendment Acts were promulgated: Rates and Monetary Amounts and Amendment of Revenue Laws Act 22 of 2020.Taxation Laws Amendment Act 23
See MoreOECD: Tax and Development Briefings
On 29 January 2021, to mark the annual Tax and Development Day, the OECD hosted a series of briefings in relation to tax and development, looking at OECD work in the area. BEPS and the extractive industries For decades many resource-rich
See MoreOECD: Public Consultation on minimum standard under BEPS Action 14
On 1 February 2021 a virtual public consultation meeting was held as part of the review of BEPS Action 14 on improving tax dispute resolution mechanisms. This follows the publication of a consultation document in November 2020 and the publication
See MoreSingapore: IRAS issues updated tax guide on R&D tax measures
On 29 January 2021, the Inland Revenue Authority of Singapore (IRAS) issued an updated e-Tax Guide on Research and Development (R&D) Tax Measures (6th Edition). The Guide sets out the relevant R&D tax measures as announced in Budgets
See MoreOECD: Meeting of the Inclusive Framework on BEPS
The 11th plenary meeting of the OECD/G20 Inclusive Framework on base erosion and profit shifting (BEPS) was held on 27 and 28 January 2021 as a virtual meeting. The countries involved in the Inclusive Framework are working towards implementation of
See MoreUS and Argentina sign CbC exchange arrangement
On 27 January 2021, US and Argentina have signed a competent authority agreement to exchange country-by-country reports. The purpose of the agreement is to increase international tax transparency and improve access of their respective tax
See MoreMalta: CFR notifies about DAC6 reporting deadline
On 29 January 2021, the Maltese Commissioner for Revenue (CFR) has notified that with respect to cross-border arrangements where the trigger point for reporting took place between 1 July 2020 and 31 December 2020, the deadline for reporting must
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