Vietnam: MoF proposes extension of certain tax payment deadline due to COVID-19
On 17 February 2021, the Vietnamese Ministry of Finance (MoF) has issued a press release regarding the extension of certain tax payment deadline due to the COVID-19 pandemic. MoF proposes to the Government to extend the deadline of certain tax
See MoreSingapore: Summary of tax changes in Budget 2021
On 16 February 2021, the following tax changes were announced by Deputy Prime Minister and Minister for Finance, Mr. Heng Swee Keat, in his Budget Statement for the Financial Year 2021. Tax measures in the budget 2021 concern: Investment
See MoreFrance: Court makes decision to reflect intra-group financial transactions
The French tax administration (FTA) published some decisions issued by the French courts and an administrative guidance regarding the arm’s length nature of intragroup financial transactions. Court’s decisions: In the last quarter of
See MoreCroatia: Government fixes related party interest rate for 2021
The Croatian Government has changed the arm’s length interest rate from 3.42% per annum to 3% per annum regarding loans between related parties for the year 2021. This rate is effective from 1st January 2021 and applies for loans between resident
See MoreGermany: Parliament further extends the deadline for 2019 tax returns
On 12 February 2021, the Germany’s upper house of Parliament further approved an extension in the deadline for 2019 tax returns. Accordingly, the deadline for the 2019 calendar year for tax returns submitted by tax advisors is extended up to 31
See MoreCanada: CRA announces not to pay cost recovery charge for APAs
On 5 February 2021, the Canada Revenue Agency (CRA) announced that they will no longer require taxpayers to provide a cost recovery charge when entering the Advance Pricing Arrangement (APA) program. Previously, the charge was used to cover the
See MoreGreece: Tax Authority describes interest deduction limitation rules
On 11 January 2021, the Greek Public Revenue Authority (AADE) published Circular Ε. 2004 of 11 January 2021, which describes the application of the rule of limitation of interest as amended from 1 January 2019. According to the Circular, the
See MoreOECD: Final Batch of Stage 1 Peer Review Reports on Dispute Resolution
On 16 February 2021 the OECD issued the final batch of stage 1 peer review assessments in relation to BEPS Action 14 on making dispute resolution mechanisms more effective. Countries that are members of the OECD’s Inclusive Framework on BEPS
See MoreOECD: Enterprise Risk Management Maturity Model
On 9 February 2021 the OECD made available on its website a copy of the Enterprise Risk Management Maturity Model. Maturity models are a tool allowing tax administrations to reach an understanding of their levels of capability in certain
See MoreQatar: Request to extend CIT return submission deadline by 28 February 2021
Generally, corporate income tax (CIT) filing deadline for year ended 31 December 2020 will be 30 April 2021. According to the Article 30 of the executive regulations of the Income Tax Law No. 24 of 2018, the General Tax Authority (GTA) may grant an
See MoreSouth Africa: Court makes a decision regarding TP methods
On 7 January 2021, in the case of: ABC (Pty) Ltd v. Commissioner (IT 14305) ZATC 1, the South African Court upheld a transfer pricing adjustment for a taxpayer that failed to have transfer pricing documentation to support the arm’s
See MoreIreland: Revenue issues eBrief regarding guidance on CFC rules
On 12 February 2021, the Irish Revenue issued eBrief No. 027/21, which provides updated guidance regarding controlled foreign company (CFC) rules. On the similar day, the Revenue also published a Tax and Duty Manual, providing guidance of how to
See MoreDenmark: Government introduces new anti-avoidance rule
On 27 January 2021, the Government submitted a draft bill L 150, which proposes to introduce two defensive measures against the countries on the EU list of non-cooperating tax jurisdictions. According to the proposal, the Law will enter into force
See MoreArgentina: AFIP extends payment facility for SMEs
On 26 January 2021, the Federal administration of Public Revenue (AFIP) published General Resolution 4917/2021 of 26 January 2021 regarding the extension of tax payment facility for small and medium enterprises (SMEs) from 31 January 2021 until 31
See MoreFrance: Government publishes a country list with no CbC reporting obligation
On 3 February 2021, Government published a Decree of 3 February 2021, amending the order of July 6, 2017 amended in accordance with II of article 223 quinquies C of the general tax code. The decree comes into force the day after its publication.
See MoreLuxembourg: Parliament adopts Law on tax return deadline extension for 2019 and 2020
On 9 February 2021, the Luxembourg Parliament has adopted a draft law which was announced in December 2021 regarding the tax return filing deadline extension for 2019 and 2020 due to the COVID-19 pandemic. The deadlines are set for individual
See MoreBelgium plans to launch further TP audit cycle
On 11 January 2021, a number of selected Belgian taxpayers received a transfer pricing (TP) questionnaires from the tax authority’s special TP audit department. Based on noncompliant TP forms again audit cycles will be launched by the special TP
See MoreEl Salvador: Ministry of Finance publishes interest rates for late tax payment
On 29 January 2021, the El Salvador's Ministry of Finance has issued a notice regarding interest rates for late tax payments during the period 1 February to 31 July 2021. This includes an annual interest rate of 6.77%, which is increased to 10.77%
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