OECD: Request for input on proposed changes to commentary on Article 9 of OECD Model
On 29 March 2021 the OECD issued a public discussion draft on proposed changes to the commentary to Article 9 (associated enterprises) of the OECD Model Tax Convention. The amendments are to be included in the next update of the OECD
See MoreOECD: ICAP Awareness Sessions
The OECD is holding virtual Awareness Sessions on 30 March 2021 and 1 April 2021 for multinational groups looking for more information on the International Compliance Assurance Program (ICAP). Background The ICAP was set up as a voluntary
See MoreNigeria: FIRS issues a notice regarding process for making CIT payments
On 29 March 2021, the Federal Inland Revenue Service issued a notice, which clarifies application process of how to remit corporate income tax (CIT) payments in installments. The first installment must be done on or before the due date of
See MoreGreece deposits BEPS MLI ratification instrument
On 30 March 2021, the OECD announced that Greece has deposited its ratification instrument for the Multilateral Convention to Implement Tax Treaty Related Measures to Prevent Base Erosion and Profit Shifting (MLI). The MLI will enter into force for
See MoreMalaysia announces new economic package for COVID-19
On 27 March 2021, the Malaysian government issued its second stimulus package to combat the economic impact of the COVID-19 pandemic. The main tax measures are: Tax breaks on tourism extended till Dec. 31. In the previous stimulus package,
See MoreIreland: Revenue publishes an eBrief to update guidance on anti-hybrid rules
On 29 March 2021, the Irish Revenue published an eBrief No. 068/21 to announce a manual to update the guidance on anti-hybrid rules. On the similar day, the Revenue also published a Tax and Duty Manual, which provides guidance on the anti-hybrid
See MoreUS: IRS releases announcement and report concerning APMAs program
On 23 March 2021, the US IRS released an advance version of Announcement 2021-6 regarding the Advance Pricing and Mutual Agreement (APMA) program’s annual report on advance pricing agreements (APAs) for 2020. This twenty-second report
See MoreJapan: National Diet passes tax reform measures for 2021
On 26 March 2021, the National Diet (Parliament) passed the bill tax reform proposals for 2021 providing the following tax measures. A digital transformation-related investment under a certified business adaptation plan made by 31 March 2023 up
See MoreCosta Rica: Ministry of Finance issues resolution on APA procedures
On 24 March 2021, the Costa Rican Ministry of Finance released a Resolution No. DGT-R-14-2021, providing new guidelines on advance pricing agreements (APAs). The resolution provides the details guidelines of APAs procedures including definitions
See MoreUS: IRS publishes revised CFC practice unit guidelines
On 22 March 2021, the U.S. Internal Revenue Service has published a revised international practice unit on Receipt of Dividends or Interest from a Related CFC. This Unit was revised to include the extension of the IRC 954(c)(6) look through rule
See MoreOECD: Profiles for Countries Applying Arbitration under the MLI
On 23 March 2021 the OECD published Arbitration Profiles for 30 jurisdictions that are applying the arbitration provisions in Part VI of the Multilateral Convention to Implement Tax Treaty Related Measures to Prevent Base Erosion and Profit
See MoreUK: Research on Small Businesses Adopting MTD for VAT
On 23 March 2021 HMRC published the results of research carried out by an independent organisation into how Making Tax Digital (MTD) for VAT has affected small business, and to look at the costs and benefits of adopting MTD. The research focused
See MoreCroatia: Tax Administration extends submission deadline of tax return 2020
Due to COVID-19 outbreak, the tax administration made an update to their tax information related to the emergency page in March 2021. This contains an extension of the 2020 tax return, other related forms and reports submission deadline until 30
See MorePuerto Rico extends tax returns and payments deadlines due to COVID-19 outbreak
On 23 March 2021, the Puerto Rico Treasury Department (PRTD) has issued Administrative Determination No. 21-04 extending the due date for income tax returns and tax payments due to the ongoing COVID-19 pandemic. As a general rule, individuals,
See MoreSlovenia extends the deadlines for annual reports and tax returns
On 17 March 2021, the Slovenian Ministry of Finance released an announcement providing the extension of deadlines for annual reports and tax returns by one month. Accordingly, the deadline for submitting reports to the Agency of the Republic of
See MoreMorocco declares maximum interest rate 1.63% on shareholder loans
On 18 March 2021, Morocco has published Ministerial Decree 423.21 in the Official Gazette regarding the reduction of maximum interest rate for loans granted by direct shareholders from 2.23% to 1.63% for FY 2021. Interest expense on loans will
See MoreUK adopts CbC reporting XML schema 2.0
The UK tax authority has updated the country-by-country (CbC) reporting schema to XML 2.0 for submissions to HM Revenue & Customs (HMRC). All CbC reports must use the new 2.0 XML format and submitted to HMRC on or after 1 January 2021. The
See MoreNamibia: MOF publishes the 2021/22 Budget Statement
On 17 March 2021, the Ministry of Finance has published the budget statement for 2021/22 providing the following tax reforms: There were no proposed increases or changes to the main tax brackets.Budgeted expenditure for the 2022 year will be
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