Denmark: High Court makes a decision against tax authority’s TP approach
On 5 October 2020, the High Court made a decision on a case entitled “Denmark vs. Shoe Group A/S” against the tax administration’s transfer pricing (TP) approach. The tax administration of Denmark used various theories to claim that a
See MoreDenmark: National tax court clarifies TP documentation rules for intergroup companies
On 24 September 2020, the Danish Tax Administration published a Decision No. SKM2020.387.LSR, clarifying the transfer pricing documentation requirements for a change of business structure within a group company. The case concerns a Danish
See MoreRomania introduces installment option for unpaid tax in response to Covid-19 outbreak
On 4 October 2020, the Ministry of Finance of Romania declared a tax payment installment option for companies that have been affected by the Covid-19 pandemic and have unpaid tax liabilities that arose after 16 March 2020. The installment option
See MoreNigeria: President presents 2021 Budget proposals
On 8 October 2020, the President, Muhammadu Buhari, presented the Federal Budget proposals for the year 2021 at the Joint Session of the National Assembly. The recent developments in this draft Budget includes: The draft 2021 Budget, themed
See MoreIceland: Parliament approves a bill to implement tax measures under 2021 budget
On 1 October 2020, the Icelandic Parliament approved a Bill No.5 in order to implement tax measures under the 2021 budget. The bill includes the following measures; Taxes on carbon, alcohol and tobacco, oil, and car tax increased by
See MoreUS: Final Withholding Regulations on Transfer of Partnership Interest by Foreign Partner
On 7 October 2020, the IRS issued final regulations on the withholding rules for transfers of partnership interests by foreign transferors. A gain on the sale or disposition by a non-US partner of an interest in a partnership that engaged in a
See MoreBelgium publishes a new guidance on loss carryback
Belgium has published Circular 2020/C/122 regarding guidance on the application of the loss carryback provisions for companies and individual entrepreneurs due to the Covid-19 outbreak. To claim the relief, companies are required to comply with
See MoreIreland: Finance Minister delivers 2021 Budget Statement
On 13 October 2020, the Finance Minister, Paschal Donohoe, presented the 2021 Budget Statement. The Budget basically underpins the Government’s support for the economy in the face of Covid-19 pandemic. Some of the tax measures included in the
See MoreBelgium: Further extension of deadline for CIT return and local file
On 12 October 2020, the Ministry of Finance declared further extension of the deadline for filing corporate income tax (CIT) return to 16 November 2020 for Assessment Year 2020. Previously, the corporate income tax returns filing deadline had been
See MoreZambia: MOF presents the budget for 2021 to the National Assembly
On 25 September 2020, the Minister of Finance (MOF) presented the budget for 2020 to the National Assembly. Under the budget the following important amendments to the Income Tax Act will take effect from 1 January 2021: Corporate tax
See MoreAustralia: Guidance on Anti-abuse rules in tax treaties
On 12 October 2020, Australian taxation office (ATO) release new guidance about the general anti-abuse rules in any of Australia's tax treaties has been finalized and published. Law Administration Practice Statement PS LA 2020/2 Administering
See MoreWorld Tax Brief: October 2020
AlgeriaSubmission of returns: Due to the COVID-19 pandemic, the Government provides policy measures for small business and SMEs. The subscription deadline for the annual results declaration (balance sheet and appendices) is extended until 30 June
See MoreGermany: Lower house of Parliament approves BEPS MLI
On 8 October 2020, the German federal parliament (lower house) passed a law to ratify the Multilateral Convention to Implement Tax Treaty Related Measures to Prevent Base Erosion and Profit Shifting (MLI). After completion of the ratification
See MorePoland: Transfer pricing changes in recent tax law
On 29 September 2020, a draft bill amending the corporate income tax (CIT) laws was submitted to the lower house of the Polish parliament. The amendments include following proposals related to transfer pricing. Extends the application of the
See MoreEgypt issues Law on taxation of capital gains and dividends distribution
On 30 September 2020, the Egyptian Government has published Law No. 199 in the official gazette. The Law contains amendments to the income tax law around capital gains and dividends distribution and certain articles of the stamp tax law with effect
See MorePeru issues resolution on international merger operation between two non-domiciled companies
On 6 October 2020, the Peruvian tax authorities (SUNAT) issued Resolution No. 061-2020-SUNAT / 7T0000 Official Website, through which the following has been concluded: The permanent establishment must maintain the same RUC number and notify
See MoreOECD: Report on Blueprint for Pillar Two of Digital Economy Taxation
On 12 October 2020 the OECD introduced a report on the Pillar Two Blueprint on digital economy taxation. Pillar Two aims to ensure that large multinational enterprises pay a minimum level of tax regardless of the location of their headquarters
See MoreArgentina: AFIP further extends suspension of prosecution proceedings for tax collection
On 29 September 2020, the Federal Administration of Public Revenue (AFIP) published General Resolution 4828/2020 of 29 September 2020, which extends the suspension of the initiation of prosecution proceedings for the collection of taxes from 30
See More