US: IRS publishes additional guidance on base erosion and anti-abuse tax
On 1 September 2020, the Internal Revenue Service issued final regulations providing additional guidance on the base erosion and anti-abuse tax (BEAT). To limit profit-shifting, the Tax Cuts and Jobs Act (TCJA) added a new tax, the BEAT. The
See MoreTransfer Pricing Brief: September 2020
AustraliaFinancial transactions-Restriction on interest deduction: On 12 August 2020, the Australian Taxation Office (ATO) released its finalized practical guidance dealing with the application of the arm’s length debt test (ALDT) which applies
See MoreOECD: Tax Policy Reforms 2020
On 3 September 2020 the OECD issued Tax Policy Reforms 2020 setting out the reforms introduced by OECD countries and by Argentina, Indonesia and South Africa in the past year. This issue also includes China for the first time. The publication
See MoreMalta issues Regulations on temporary support measures amid COVID-19
On 25 August 2020, Malta has issued Legal Notice No. 345, which clarifies Regulations on research and development (R&D) tax credits for corporate income and individual income tax in response to the COVID-19 pandemic. The Legal Notice includes
See MoreSouth Korea: National Tax Service investigates MNEs tax evasion
On 27 August 2020, the South Korean National Tax Service has announced that it has initiated a tax audit on 21 multinational enterprises (MNEs) suspected of cross-border and committing tax evasion and 22 offshore tax evasion suspects, including
See MoreArgentina: AFIP announces additional suspension regarding inspections, assessments, appeals
On 18 August 2020, the Federal Administration of Public Revenue published General Resolution 4794 of 18 August 2020, which provides an additional postponement in case of inspections, assessments, appeals, reimbursements, other methods related to
See MoreOECD: Global Forum issues peer review reports on transparency and exchange of information
On 1 September 2020 the OECD’s Global Forum on Transparency and Exchange of Information for Tax Purposes issued nine new second-round peer review reports containing details of their review and assessment of the compliance by nine jurisdictions
See MoreUN: Subcommittee considers article on taxation of automated digital services
The subcommittee on tax challenges of the digital economy of the UN Committee of Experts on International Cooperation in Tax Matters held a meeting from 25 to 27 August 2020. The subcommittee considered the proposed new Article 12B to the UN
See MoreEgypt: Parliament approves BEPS multilateral instrument (MLI)
On 18 August 2020, the Egyptian House of Representatives (Parliament of Egypt) has approved several presidential decrees on international agreements. Among the agreements, the Parliament has approved the Multilateral Convention to Implement Tax
See MoreDenmark: Ministry of Taxation publishes a Bill regarding deduction for R&D expenses
The Ministry of Taxation has recently published a draft Bill, which provides an increase in the allowed deduction of R&D expenses up to 130% for the 2020 and 2021 tax years to give support to companies and investment during COVID-19 pandemic.
See MoreNew Zealand: Inland Revenue releases guidance on transfer pricing amid COVID-19
Recently, New Zealand’s Inland (IR) Revenue has released guidance regarding practice issues for transfer pricing due to the COVID-19 pandemic. The COVID-19 pandemic has created an impact on specific sectors and businesses substantially. The
See MoreCanada: CRA further extends the application periods regarding international tax issues
On 31 August 2020, the Canadian Revenue Agency published a Guidance in their website to announce further extension of the application period until 30 September 2020 on various international tax issues arising due to COVID-19. This Guide includes
See MoreWorld Bank: Vietnam must boost new drivers of growth
On 30 July 2020 the World Bank issued an economic update entitled What will be the new normal for Vietnam: the economic impact of COVID-19?. Vietnam has been successfully fighting the COVID-19 crisis but GDP growth has suffered a fall of almost
See MoreThailand: Special tax relief measures for SME sector
The Thai Ministry of Finance has released the Royal Decree No. 707 and 708 regarding tax relief measures for SMEs in response to the Covid-19 pandemic, with effect from 13 July 2020. The Royal Decree No. 707 permits eligible SMEs that affected
See MorePakistan: FBR approves the Audit Policy 2019
On 26 August 2020, the Pakistan Federal Board of Revenue (FBR) announced the approval of the Audit Policy 2019. The Audit Policy 2019 shall apply to persons or classes of persons falling under all or any of the three domestic Federal Tax Statutes
See MoreIMF: Effect of the COVID-19 Crisis on Lower Income Developed Countries
An IMF blog post, dated 27 August 2020, notes that the low income developing countries (LIDCs) are in a difficult position to combat the COVID-19 crisis. They have already been hard hit by external shocks and the lockdown measures are causing their
See MoreBrazil: Chamber of Deputies considers new draft Bill regarding digital service tax
On 19 August 2020, a Bill 218/2020, the social contribution on digital services (CSSD), was submitted and considered by the Chamber of Deputies, which provides the introduction of digital service tax (DST). Previously, On 4 May 2020, Mr. João
See MoreUkraine: SFS releases guidance letter on new CFC rules
On 17 August 2020, the Ukraine State Fiscal Service (SFS) has issued a guidance letter 3380/IPK/99-00-05-05-02-09, which clarifies the taxation of profits of controlled foreign companies (CFCs). In Ukraine, the CFC rule will be applicable from 1
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