OECD: Inclusive Framework Signs Agreement on Two Pillar Solution
On 8 October 2021 a total of 136 member countries of the OECD/G20 Inclusive Framework on BEPS joined the Statement on the Two-Pillar Solution to Address the Tax Challenges Arising from the Digitalisation of the Economy. The Statement finalised
See MoreWorld Tax Brief: October 2021
ArgentinaWithholding tax on dividends: On 26 August 2021, the Federal Public Revenue Administration (AFIP) published General Resolution 5060/2021 to update previous General Resolution 4478/2019. Accordingly, this update eliminates the alternative
See MoreTurkey: Parliament members submit a new Tax Bill to the Parliament
On 1 October 2021, Turkish Parliament members have submitted a new Tax Bill to the Parliament which includes tax filing periods, tax exemptions, and incentives. The key corporate tax measures of the Bill are: In the reduced corporate tax
See MoreUS: CRS releases report on tax provisions in the “Build Back Better Act”
On 28 September 2021, the U.S. Congressional Research Services (CRS) has published a report on the tax provisions in the legislative recommendations for the budget reconciliation legislation, also known as the “Build Back Better Act. The
See MoreIMF Report Discusses Developments in the Netherlands
On 28 September 2021 the IMF issued a report on the Netherlands economy following consultations under Article IV of the IMF’s articles of agreement. The report notes that the Netherlands economy suffered a relatively small recession in the
See MoreFinland: Supreme court makes a decision on arm’s length range and TP adjustment
On 13 September 2021, the Finnish Supreme Administrative Court (SAC) published a decision addressing the use of comparable data and the range of results in calculating transfer pricing adjustments. The case concerned a company, Finnish A Oy,
See MorePoland: Lower chamber of parliament passes the tax reform bill
On 1 October 2021, the lower chamber of parliament (the Sejm) of Poland has passed the 3rd reading the bill for the so-called “Polish Deal” tax reform bill. The bill proposes to several tax reform measures including new minimum corporate tax,
See MorePoland: Government plans to extend the scope of CFC rules
On 8 September 2021, the Polish government submitted a bill to the Parliament including the proposal extending the application of the CFC rules. The proposal includes the following changes: Extension of the definition of a foreign legal entity
See MoreUK: Statistics on Research and Development Tax Relief
On 30 September 2021 HMRC published the statistics for claims for research and development (R&D) tax relief in the UK. The statistics on tax relief schemes allow the government to monitor the level of use of the incentive schemes and make an
See MoreUK: Soft Drinks Industry Levy Statistics
On 30 September 2021 the UK government published the latest statistics on revenue collected from the soft drinks industry levy (SDIL). The UK introduced the SDIL in April 2018 after public consultation with the industry and other interested
See MoreTransfer Pricing Brief: October 2021
BotswanaDocumentation-Thresholds: On 1 September 2021, the General Commissioner published a ruling which sets the threshold for the preparation and submission of transfer pricing documentation. Accordingly, the obligation to prepare and submit
See MoreUK: Patent Box Relief Statistics Updated
Under the patent box legislation in the UK companies can enjoy a lower rate of UK corporation tax on their profits earned from qualifying patented inventions and some other equivalent types of intellectual property. The patent box relief was
See MoreUkraine: STS clarifies about taxation of dividends received
On 3 September 2021, the Ukrainian State Tax Service (STS) has clarified that in case of dividends received by a legal entity from another legal entity under a simplified tax regime, the dividends that have not been taxed under the Tax Code of
See MoreIndia extends the validity of transfer pricing safe harbor rules
On 24 September 2021, the CBDT issued a new Notification No. 117/2021, to extend the applicability of the transfer pricing safe harbor rules. The extension applies for the 2020-21 and 2021-22 assessment years. Taxpayers opting for safe harbor rules
See MorePuerto Rico: Treasury Department clarifies guidance on transfer pricing studies
On 20 September 2021, the Puerto Rico Treasury Department (PRTD) has issued Administrative Determination (AD) No. 21-08, which amends AD No. 21-05 of 11 May 2021. The AD 21-08 clarifies guidance on submitting transfer pricing studies (TPS). AD
See MoreWorld Bank: Taxation of the Digital Sector
On 1 October 2021 the Third World Bank Tax Conference discussed the taxation of the digital sector. Value added tax collection The growth of the digital economy has changed business models and has presented new problems for tax assessment and
See MoreWorld Bank: Conference looks at implementation of new tax instruments
On 1 October 2021 the second day of the Third World Bank Tax Conference looked at the practical implementation of new tax instruments. Sugar tax in South Africa The sugar-sweetened beverage tax in South Africa was first announced in the 2016
See MoreWorld Bank: Third Tax Conference Discusses Environmental Taxes
The first day of the Third World Bank Tax Conference on 30 September 2021 included a session on environmental taxes, focusing on carbon pricing and carbon taxes. Some issues raised in the discussion are summarised below. Carbon rebate
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