IMF Report Looks at Economic Developments in Germany
On 19 January 2021 the IMF issued a report following the conclusion of its consultations with Germany under Article IV of the IMF’s articles of agreement. As a result of the COVID-19 pandemic and the domestic containment measures Germany’s
See MorePlatform for Collaboration on Tax: Toolkit on Implementing Transfer Pricing Documentation Requirements
On 19 January 2021 the Platform for Collaboration on Tax (PCT) published the “Practical Toolkit to Support the Successful Implementation by Developing Countries of Effective Transfer Pricing Documentation Requirements”. The PCT was set up by
See MoreDenmark: Court supports a decision on a case regarding intra-group deposits
On 18 January 2021, the National Tax Tribunal uphold a decision on a case of SKM2021.33.LSR regarding intragroup deposits with a group treasury entity, mentioning the taxpayer’s flawed documentation and differences in the interest rates charged
See MorePortugal publishes new CIT return form
Portugal has approved Order no. 314/2021 to update the corporate income tax (CIT) return forms (Modelo 22) considering legislative changes made in 2020 and the need to introduced improvements in the
See MoreEstonia deposits BEPS MLI ratification instrument
On 15 January 2021, Estonia 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 Estonia on 1 May
See MoreSwitzerland: Review on international financial and tax matters of 2020
Switzerland’s Secretariat for International Finance (SIF) has published its annual review on international financial and tax matters for 2020. With respect to tax-related matters in particular, the review includes the following: Taxing
See MoreItaly introduces APA rollback
Budget Law 2021 contains new provisions on advance pricing agreement (APA) rollback. Multinational group taxpayers that had already agreed to APAs to address their transfer pricing can now rely on their retroactivity for tax periods still open for
See MoreSouth Africa: SARS invites public comments on ATR system
On 15 January 2021, the South African Revenue Service (SARS) made a public comment session regarding the Advance Tax Rulings System. Taxpayers, tax practitioners and professional associations are invited to submit comments on the current Advance
See MoreHong Kong issues regulation on tax concessions for insurance-related businesses
On 15 January 2021, the Hong Kong’s Government gazetted subsidiary legislation to implement the new profits tax concessions for insurance-related businesses on March 19, 2021. Enacted in July 2020, the Inland Revenue (Amendment) (Profits Tax
See MoreBosnia and Herzegovina: BEPS MLI enters into force
The Multilateral Convention to execute tax agreement related measures to prevent base erosion and profit shifting (MLI) entered into force for Bosnia and Herzegovina on 1 January 2021. As regards the double taxation agreement (DTA) between Bosnia
See MorePeru issues Law on tax incentives for agribusiness
On 31 December 2020, Peru has issued Law No. 31110 in the official gazette modifying new regime and tax incentives for agribusiness. The new Law replaces previous Law No. 27360 and is effective from 1 January 2021. The Law aims to develop
See MoreOECD: Public Consultation on Tax Challenges of the Digital Economy
A public consultation meeting was held by the OECD on 14 and 15 January 2021 to discuss the proposals in relation to Pillar One and Pillar Two of the tax challenges of the digital economy. Following the publication of Blueprints on Pillar One and
See MoreSri Lanka: Budget for 2021
The Inland Revenue Department (IRD) of Sri Lanka has issued a notice to taxpayers announcing the tax proposals in the 2021 Budget recently presented in parliament. As per the National budget of 2021 presented in Parliament, following new
See MoreItaly extends DST deadlines for FY 2020
On 15 January 2021, the Italian tax authorities published Provision no. 13185/2021 regarding the implementation the procedures for the collection of the 3% digital services tax (DST). The DST is effective from 1 January 2020 in Italy. The
See MoreThailand: Tax authority prolongs e-Filing deadline extension for 3 more years
On 15 January 2021, the Thai Ministry of Finance announced that the deadlines of the e-Filing and electronic tax payment will be extended for 8 more days, after the tax filing deadlines specified by the law. The extension will be effective for 3
See MoreFrance: Supreme Administrative Court makes a decision regarding TP disputes
Recently, the Supreme Administrative Court made a decision of a case “France vs Ferragamo France” against of Administrative Court. On 23 November 2020, the Administrative Court made a decision in this case in favour of Ferragamo and dismissed
See MoreEcuador: Government make rules on advance income tax payments
On 22 December 2020, the Government Officially published a Resolution No. NAC-DGERCGC20-00000071 to describe the rules for income tax payments voluntarily instead of mandatory advance income tax payments. The Tax reform law 2020 repealed this
See MoreAlgeria: Government publishes revised TP documentation requirements
On 2 January 2021, Government Officially published a Decree of 17 November 2020, which replaces the Decree of 12 April 2012. Initial transfer pricing documentation, which is submitted with the tax return, includes: Basic documentation regarding
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